New 2024 CPT Coding Changes Affect General Surgery, Related Specialties

The American Medical Association (AMA) Current Procedural Terminology (CPT)* code set is updated annually. This year, many of the updates are time-based codes, which could affect when they may be reported. This article describes CPT 2024 coding changes that are relevant to general surgery and related specialties.

Hyperthermic Intraperitoneal Chemotherapy

Two new add-on time-based codes have been established to report intraoperative hyperthermic intraperitoneal chemotherapy (HIPEC): CPT code 96547, Intraoperative hyperthermic intraperitoneal chemotherapy (HIPEC) procedure, including separate incision(s) and closure, when performed; first 60 minutes (List separately in addition to code for primary procedure); and CPT code 96548, Intraoperative hyperthermic intraperitoneal chemotherapy (HIPEC) procedure, including separate incision(s) and closure, when performed; each additional 30 minutes (List separately in addition to code for primary procedure).

These codes are reported based on the surgeon’s total time for both face-to-face and non-face-to-face activities related to the HIPEC procedure, including chemotherapy agent selection, confirmation of perfusion equipment settings for chemotherapy agent delivery, additional incision(s) for catheter and temperature probe placement, perfusion supervision and manual agitation of the heated chemotherapy agent in the abdominal cavity during chemotherapy agent dwell time, irrigation of the chemotherapy agent, closure of wounds related to HIPEC, and documentation of the chemotherapy agent and HIPEC procedure in the medical record. When reporting 96547 and 96548, do not include time for the typical preoperative, intraoperative, and postoperative work related to the primary procedure(s) that may be separately reported (i.e., 38100-38102, 38120, 43611, 43620-43622, 43631-43634, 44010-44015, 44110-44111, 44120-44125, 44130, 44139, 44140-44147, 44150-44160, 44202-44204, 44207, 44213, 44227, 47001, 47100, 48140-48145, 48152, 48155, 49000, 49010, 49203-49205, 49320, 58200-58210, 58575, 58940, 58943, 58950-58960).

Codes 96547 and 96548 are time-based codes and therefore may not be reported until the midpoint of the time increment in the code descriptors has been reached. Specifically, code 96547 (first 60 minutes) may not be reported until at least 31 minutes has been reached unless the procedure is discontinued (e.g., the patient becomes unstable or has an allergic reaction to the chemotherapy agent), in which case modifier 53, Discontinued Procedure, should be appended to code 96547. In addition, code 96548 may only be reported after an additional 16 minutes of the HIPEC procedure above the initial 60 minutes reported with code 96547 is attained (i.e., 76 minutes of total time). As an example, if total face-to-face and non-face-to-face time related to HIPEC procedure activities is 100 minutes, you would report 96547 × 1 and 96548 × 1. You would not be able to report a second unit of 96548 until 106 minutes (60 + 30 + 16) has been reached.

For 2024, codes 96547 and 96548 will be contractor priced. Work relative value units (RVUs) are expected to be established for calendar year 2025.

Evaluation and Management and Prolonged Services Codes

For 2024, the CPT Editorial Panel has made further refinements to the evaluation and management (E/M) visit codes. They have eliminated any references to specific time ranges and, instead, introduced a minimum time requirement when using time to select a level of E/M service. These revisions were meant to counter the Centers for Medicare & Medicaid Services (CMS) policy that a full 15 minutes must be spent above the maximum time in the time range for a code before an add-on code for each additional 15 minutes could be reported. Due to CMS’s disagreement with the CPT guidelines regarding the threshold time, the agency has introduced Healthcare Common Procedure Coding System (HCPCS) Level II codes with distinct reporting instructions. This dual system of codes, CPT and HCPCS, for prolonged E/M services has led to ongoing confusion. Nevertheless, CMS remains firm in its stance that the full 15 minutes beyond the maximum time threshold, not the minimum time threshold, must be achieved before reporting a prolonged services code.

Although surgeons do not typically report an E/M service using total time on the date of the encounter, there will be instances where the total face-to-face and non-face-to-face time of both the surgeon and the surgeon’s physician assistant or nurse practitioner will exceed the time for the highest level of E/M code and it would be more appropriate to report using total time. When reporting prolonged services codes, it is important to remember that the HCPCS codes must be used for all Medicare claims. Other payers may choose to also require the HCPCS codes and CMS policies or they may allow use of the CPT prolonged services codes and CPT policy. Table 1 below provides a side-by-side comparison of the 2024 CPT and HCPCS prolonged services time threshold reporting guidelines that were effective as of the publication of this article.

Critical Care Services

Although the CPT Panel changed the code descriptors for office and hospital E/M codes to include a minimum time for reporting the code instead of a time range, the critical care code (99291, 99292) descriptors continue to include time ranges.

Table 1. CPT vs. Medicare Time Threshold for Reporting Prolonged Services

Primary E/M Service

(minimum time on date of encounter)

CPT Prolonged Services Codes

CPT Time Threshold

Medicare Prolonged Services Codes

Medicare Time Threshold

99205 New Patient Office Visit
(60 minutes)

99417

75 minutes

G2212

90 minutes

99215 Established Patient Office Visit
(40 minutes)

99417

55 minutes

G2212

70 minutes

99223 Initial Inpatient or Observation Visit
(75 minutes)

99418

90 minutes

G0316

105 minutes

99233 Subsequent Inpatient or Observation Visit
(50 minutes)

99418

65 minutes

G0316

80 minutes

99417 Prolonged outpatient evaluation and management service(s) time with or without direct patient contact beyond the required time of the primary service when the primary service level has been selected using total time, each 15 minutes of total time (List separately in addition to the code of the outpatient Evaluation and Management service).

99418 Prolonged inpatient or observation evaluation and management service(s) time with or without direct patient contact beyond the required time of the primary service when the primary service level has been selected using total time, each 15 minutes of total time (List separately in addition to the code of the inpatient and observation Evaluation and Management service).

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, 99483 for office or other outpatient evaluation and management services) (Do not report G2212 on the same date of service as 99358, 99359, 99415, 99416) (Do not report G2212 for any time unit less than 15 minutes).

G0316 Prolonged hospital inpatient or observation care evaluation and management service(s) beyond the total time for the primary service (when the primary service has been selected using 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 99223, 99233, and 99236 for hospital inpatient or observation care evaluation and management services) (Do not report G0316 on the same date of service as other prolonged services for evaluation and management 99358, 99359, 99418, 99415, 99416) (Do not report G0316 for any time unit less than 15 minutes).

Primary E/M Service (minimum time on date of encounter)	CPT Prolonged Services Codes	CPT Time Threshold	Medicare Prolonged Services Codes	Medicare Time Threshold
99205 New Patient Office Visit (60 minutes)	99417	75 minutes	G2212	90 minutes
99215 Established Patient Office Visit (40 minutes)	99417	55 minutes	G2212	70 minutes
99223 Initial Inpatient or Observation Visit (75 minutes)	99418	90 minutes	G0316	105 minutes
99233 Subsequent Inpatient or Observation Visit (50 minutes)	99418	65 minutes	G0316	80 minutes
99417 Prolonged outpatient evaluation and management service(s) time with or without direct patient contact beyond the required time of the primary service when the primary service level has been selected using total time, each 15 minutes of total time (List separately in addition to the code of the outpatient Evaluation and Management service).
99418 Prolonged inpatient or observation evaluation and management service(s) time with or without direct patient contact beyond the required time of the primary service when the primary service level has been selected using total time, each 15 minutes of total time (List separately in addition to the code of the inpatient and observation Evaluation and Management service).
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, 99483 for office or other outpatient evaluation and management services) (Do not report G2212 on the same date of service as 99358, 99359, 99415, 99416) (Do not report G2212 for any time unit less than 15 minutes).
G0316 Prolonged hospital inpatient or observation care evaluation and management service(s) beyond the total time for the primary service (when the primary service has been selected using 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 99223, 99233, and 99236 for hospital inpatient or observation care evaluation and management services) (Do not report G0316 on the same date of service as other prolonged services for evaluation and management 99358, 99359, 99418, 99415, 99416) (Do not report G0316 for any time unit less than 15 minutes).

This has resulted in CPT and CMS having different instructions about when it would be appropriate to report code 99292 for each additional 30 minutes of critical care services. Similar to the discussion above for office and hospital visit E/M codes, CMS requires a full 30 minutes of service above the maximum time in the time range for 99291, while CPT instructs that 99292 can be reported after one minute or additional time.

When reporting critical care services codes, it is important to remember that the CMS policy must be used for all Medicare claims. Other payers may choose to follow the CMS policy or they may allow use of the CPT policy. Table 2 below provides a side-by-side comparison of the CPT and CMS policies for correctly reporting codes 99291 and 99292.

Hospital Inpatient or Observation Care Services for Short Stays

Prior to 2024, the CPT codebook was silent on the length of stay or amount of time required to report separate inpatient or observation E/M services codes and/or discharge management E/M codes. To better align with CMS policy for reporting these services, new guidelines were added to the 2024 CPT code set to provide instructions on when it is appropriate to report codes 99234, 99235, or 99236, which describe admission and discharge on the same date. Specifically, these codes are only to be reported by a provider who performs both the initial and discharge services on a single date of service and when the patient stay is more than 8 hours. Other physicians who also provide an E/M service may report 99221-99223, as appropriate.

When a patient receives hospital inpatient or observation care for fewer than 8 hours, only codes 99221-99223 may be reported, and 99234-99236 or 99238-99239 may not be reported. For patients admitted to hospital inpatient or observation care and discharged on a different date, the appropriate level of hospital E/M service is reported on the first date and the appropriate discharge service is reported on the subsequent date. Keep in mind that only one physician may report same date admit/discharge codes 99234-99236 and two or more separate and distinct patient encounters are required to report these codes.

Table 2. CPT vs. Medicare Reporting for Critical Care Services

Total Duration of Critical Care Services

CPT Reporting Instructions

Medicare Reporting Instructions

Less than 30 minutes

99221-99231, 99231-99233

as appropriate

99221-99231, 99231-99233

as appropriate

30–74 minutes

99291 x 1

75–104 minutes

99291 x 1 and 99292 x 1

99291 x 1

105–134 minutes

99291 x 1 and 99292 x 2

99291 x 1 and 99292 x 1

135–164 minutes

99291 x 1 and 99292 x 3

99291 x 1 and 99292 x 2

165 minutes or longer

99291 and 99292

using guidelines above

99291 and 99292

using guidelines above

99291 Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes.

+99292 Critical care, evaluation and management of the critically ill or critically injured patient;
each additional 30 minutes (List separately in addition to code for primary service).

Total Duration of Critical Care Services	CPT Reporting Instructions	Medicare Reporting Instructions
Less than 30 minutes	99221-99231, 99231-99233 as appropriate	99221-99231, 99231-99233 as appropriate
30–74 minutes	99291 x 1	99291 x 1
75–104 minutes	99291 x 1 and 99292 x 1	99291 x 1
105–134 minutes	99291 x 1 and 99292 x 2	99291 x 1 and 99292 x 1
135–164 minutes	99291 x 1 and 99292 x 3	99291 x 1 and 99292 x 2
165 minutes or longer	99291 and 99292 using guidelines above	99291 and 99292 using guidelines above
99291 Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes.
+99292 Critical care, evaluation and management of the critically ill or critically injured patient; each additional 30 minutes (List separately in addition to code for primary service).

If a surgeon does not admit the patient to inpatient or observation care and instead consults on one or more days, then the surgeon should report the inpatient/observation E/M codes 99221-99223 and 99231-99233 as appropriate. Table 3 below provides a quick reference to reporting E/M services codes for short stays.

Table 3. Reporting E/M Services for Short Stays

Patient Length of Stay

Clinical Scenario

CPT Codes Reported, as Appropriate

Less than 8 hours

Patient arrives and is discharged on the same calendar date

99221, 99222, 99223

Patient arrives and is discharged on a different calendar date (e.g., arrives 11:00 pm and discharged at 5:00 am the next day)

99221, 99222, 99223 (reported on discharge date)

8 or more hours

Patient arrives and is discharged on the same calendar date

99234, 99235, 99236

Patient arrives and is discharged on a different calendar date (e.g., arrives 6:00 pm and discharged at 7:00 am the next day)

99221, 99222, 99223 (arrival date)

99238, 99239 (discharge date)

Patient Length of Stay	Clinical Scenario	CPT Codes Reported, as Appropriate
Less than 8 hours	Patient arrives and is discharged on the same calendar date	99221, 99222, 99223
Less than 8 hours	Patient arrives and is discharged on a different calendar date (e.g., arrives 11:00 pm and discharged at 5:00 am the next day)	99221, 99222, 99223 (reported on discharge date)
8 or more hours	Patient arrives and is discharged on the same calendar date	99234, 99235, 99236
8 or more hours	Patient arrives and is discharged on a different calendar date (e.g., arrives 6:00 pm and discharged at 7:00 am the next day)	99221, 99222, 99223 (arrival date) 99238, 99239 (discharge date)

Looking Forward to CPT 2025

The meeting cycle for the CPT 2025 code set has concluded, resulting in new codes and guidelines that will be effective for CPT 2025. Several changes that are important to general surgery and related specialties include: (1) Addition of five codes to report excision/destruction of intra-abdominal peritoneal, mesenteric, and/or retroperitoneal primary or secondary tumor(s)/cyst(s), revision of code 58958, and deletion of codes 49203, 49204, 49205, 58957; (2) Addition of 17 codes and guidelines for reporting telemedicine E/M office visits, addition of a new E/M subsection for Telemedicine Services, and deletion of codes 99441, 99442, and 99443; and (3) Addition of eight codes and revision of the Skin Replacement Surgery subsection guidelines to report skin cell suspension autograft procedures. Please note that codes are not assigned, nor exact wording finalized, until just prior to publication of the CPT codebook. Release of more specific CPT code set information is timed with the release of the entire set of coding changes in the CPT publication.^†

Learn More

As part of the College’s ongoing efforts to help members and their practices submit clean claims and receive proper reimbursement, a coding consultation service—the ACS Coding Hotline—has been established for coding and billing questions. ACS members are offered five free consultation units (CUs) per calendar year. One CU is a period of up to 10 minutes of coding services time. Access the ACS Coding Hotline website.

Dr. Megan McNally is a surgical oncologist at Saint Luke’s Health System in Kansas City, Missouri, and assistant clinical professor in the Department of Surgery at the University of Missouri-Kansas City School of Medicine. She also is a member of the ACS General Surgery Coding and Reimbursement Committee and an ACS advisor to the AMA CPT Editorial Panel.

^†Summary of CPT Editorial Panel action documents accessed October 10, 2023 at www.ama-assn.org/about/cpt-editorial-panel/summary-panel-actions.