Ob-Gyn Coding Alert

HCPCS Level II 2021:

Update Your Prolonged E/M, Virtual Check-Ins, and Ob-Gyn Quality Measures

For Medicare payers, start submitting G2212 instead of +99417.

As of January 1, you have a few HCPCS Level II codes to use when you bill Medicare for prolonged E/M visits, thanks to the Centers for Medicare & Medicaid Services’ (CMS’) 2021 Physician Fee Schedule (PFS) final rule.

That’s not all. You should also note two new virtual check-in codes and five ob-gyn related quality measures. Here’s the scoop.

Get the G2212 Low Down

CMS’ intent in introducing G2212 (Prolonged office or other outpatient evaluation and management service(s) beyond the maximum required time of the primary procedure which has been selected using total time on the date of the primary service; each additional 15 minutes by the physician or qualified healthcare professional, with or without direct patient contact (List separately in addition to CPT codes 99205, 99215 for office or other outpatient evaluation and management services) …) is to resolve their disagreement with CPT® over when service times for 99205 (Office or other outpatient visit for the evaluation and management of a new patient … 60-74 minutes of total time is spent on the date of the encounter) or 99215 (Office or other outpatient visit for the evaluation and management of an established patient … 40-54 minutes of total time is spent on the date of the encounter) enter prolonged territory.

CPT®’s instructions for +99417 (Prolonged office or other outpatient evaluation and management service(s) beyond the minimum required time of the primary procedure which has been selected using total time, requiring total time with or without direct patient contact beyond the usual service, on the date of the primary service, each 15 minutes of total time (List separately in addition to codes 99205, 99215 for office or other outpatient Evaluation and Management services)) tell you to add the code onto 99205 or 99215 when these codes hit one minute beyond the maximum in their time ranges - 75 minutes for the new patient visit and 55 for the established.

In the final rule, however, CMS has finalized their proposal that you add a prolonged code when the time for visits hits 15 minutes beyond the maximum time range for 99205 (i.e., 89 minutes) and 99215 (i.e., 69 minutes). To avoid the potential confusion with CPT® guidelines that this would cause, they have abandoned +99417 and replaced it with G2212.

CMS’ adoption of G2212 is unfortunate, however, as it means your ob-gyn practice “will have to bill Medicare differently for prolonged office visits than they do payers who follow CPT®. That means more administrative complexity, which is the last thing [practices] need these days,” says Kent Moore, senior strategist for physician payment at the American Academy of Family Physicians.

Check Out These Virtual Additions

Additionally, when you report a virtual check-in for a Medicare patient, you’ll have two new HCPCS codes from which to choose. They are:

  • G2251 (Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of clinical discussion)
  • G2252 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion).

You’ll need to make sure this entails audio-only real-time telephone interactions in addition to synchronous, two-way interactions enhanced by video or other data transmission. Make sure the ob-gyn documents direct interaction between the ob-gyn and the patient.

Also, CMS will expect the patient to initiate these services.

Remember Quality Measures? You’ve Got These New Ones

Finally, you have two new ob-gyn related quality measures. They are:

  • G9355 (Early elective delivery by c-section, or early elective induction, not performed (less than 39 weeks gestation)
  • G9356 (Early elective delivery by c-section, or early elective induction, performed (less than 39 week gestation)

“These quality measures are normally only recognized by Medicaid or Medicare as they are ‘G’ codes, but it is always prudent to check with your commercial payers in case they also have developed quality programs that would make reporting these advantageous to the practice,” says Melanie Witt, RN, MA, an independent coding expert based in Guadalupita, New Mexico.

Deletions: You should know longer consider these Rh-immunoglobulin quality measures as options in 2021:

  • G8809 (Rh-immunoglobulin (rhogam) ordered)
  • G8810 (Rh-immunoglobulin (rhogam) not ordered for reasons documented by clinician (e.g., patient had prior documented receipt of rhogam within 12 weeks, patient refusal)
  • G8811 (Documentation rh-immunoglobulin (rhogam) was not ordered, reason not given).

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