ACR Urges Elimination of Duplicative, Controversial G Code

A coalition of physician and non-physician clinicians led by the American College of Radiology® (ACR®) this week pressed federal lawmakers (Senate letter, House letter) to permanently halt the implementation of Healthcare Common Procedure Coding System (HCPCS) code G2211.

G2211 is a Centers for Medicare and Medicaid Services (CMS)-generated add on code to be billed with evaluation and management (E/M) codes. CMS intended for it to further reflect patient complexity, however, the code has been controversial since initially finalized for implementation in 2021. ACR and many other physician and non-physician providers, along with the Medicare Payment Advisory Commission (MedPAC) and the AMA/Specialty Society Relative Value Scale Update Committee believe the code to be duplicative as increased patient complexity was already accounted for in the outpatient E/M revaluation that was finalized and implemented in 2021.

In response to this controversy in 2021, Congress delayed implementation of the code until at least 2024. In the 2024 Medicare Physician Fee Schedule (MPFS) proposed rule, CMS proposes moving forward with implementation of G2211 and estimates that it is responsible for 90% of the overall budget neutrality reduction to the conversion factor.

The ACR-led coalition will continue to advocate for both permanent reform to the MPFS and short-term relief to provide radiologists with the fiscal stability needed to continue to provide Medicare beneficiaries with optimal patient care.

For more questions, contact Rebecca Spangler, ACR Senior Government Affairs Director.