G0545 – The Other Inherent Complexity Code
Image by Pexels: CDC
CMS introduced a new HCPCS code for 2025 to capture the intensity and complexity of hospital inpatient or observation care for confirmed or suspected infectious diseases, provided by a physician with specialized training in infectious diseases.
G0545 – Visit complexity inherent to hospital inpatient or observation care associated with a confirmed or suspected infectious disease by an infectious diseases specialist, including disease transmission risk assessment and mitigation, public health investigation, analysis, and testing, and complex antimicrobial therapy counseling and treatment (add-on code, list separately in addition to hospital inpatient or observation evaluation and management visit, initial, same day discharge, subsequent or discharge).
(CMS Hou 18: Fee – $44.25) (wRVU – 0.89)
Similar to G2211, the Federal Register provides limited information on documentation requirements but suggested the following be included.
1. Disease Transmission Risk Assessment and Mitigation
- Developing, following, and supervising specialized, individualized infection control protocols for an individual patient based on their diagnosis and risks in order to reduce risk of disease transmission.
- Coordinating with human resources regarding infection prevention and control measures to enable healthcare facility staff to safely care for patient.
- Counseling patients, family members and caregivers regarding infection prevention.
- Managing infection prevention and treatment protocols associated with transitions of care for complex patients.
2. Public Health Investigation, Analysis, and Testing
- In-depth patient chart review that entails going back farther in time and assessing the complete breadth of all health care interactions, with higher-level synthesis for complex diagnoses.
- Communicating with the clinical microbiology lab and directly reviewing specimens.
- Coordinating specialized diagnostic evaluations (for example, identifying and facilitating diagnostic laboratory tests only available at specialized laboratories, the state health department, and/or the Centers for Disease Control & Prevention).
- Coordinating with Federal, State and local public health agencies and laboratories to assist with contact tracing, obtaining specimens for specialized testing, and/or identifying prior testing and treatment for communicable diseases in other jurisdictions.
3. Complex Antimicrobial Therapy Counseling & Treatment
- Counseling patients, family members, and caregivers regarding antimicrobial stewardship and resistance for the patient.
- Engaging in complex medical decision-making associated with antimicrobial prescribing including considerations such as antimicrobial resistance patterns, emergence of new variants/strains, recent antibiotic exposure, interactions/complications from comorbidities including concurrent infections, public health considerations to minimize development of antimicrobial resistance, and emerging and re-emerging infections.
As new information emerges, I will update this post accordingly.
Resources
IDSA – G0545 Fact Sheet