Clinicians participating in the Making Care Primary (MCP) model now have access to two new HCPCS Level II codes, HCPCS Codes G9037 and G9038, introduced in fiscal year (FY) 2024. These codes expand the scope of interprofessional consultation services, allowing primary care providers (PCPs) to bill for time spent collaborating with specialists.
The MCP Model: Advancing Primary Care
The MCP model is a groundbreaking value-based care initiative launched on July 1, 2024, running through December 31, 2034, across eight states:
- Colorado, North Carolina, New Jersey, New Mexico, Minnesota, Massachusetts, Washington, and New York.
Designed to strengthen care coordination, the model includes three participation tracks to help PCPs gradually transition to prospective population-based payments. One key benefit of participating in alternative payment models (APMs) like MCP is eligibility for:
- Higher Medicare conversion factors (beginning in 2026)
- Exemption from the Merit-Based Incentive Payment System (MIPS)
- Model-specific performance payments
Why New G Codes Matter
More than 40% of Medicare beneficiaries see at least five physicians, making interprofessional collaboration challenging. Many PCPs struggle to receive timely, relevant information from specialists, leading to gaps in patient care. To improve care coordination, communication, and patient outcomes, the Centers for Medicare & Medicaid Services (CMS) created HCPCS Codes G9037 & G9038.
Understanding G9037: E-Consult Code
G9037 allows PCPs in Track 2 or 3 of the MCP model to bill for interprofessional consultations with specialists when developing a patient’s care plan. These e-consults can occur via:
- Asynchronous phone communication
- Audio/video synchronous technology
- Electronic health records (EHRs)
- HIPAA-compliant applications
Key Conditions for Billing G9037:
- Bill once per clinical question, regardless of the number of exchanges with the specialist.
- Cannot bill more than once per week per patient.
- Cannot bill G9037 within seven days of billing CPT® 99452 for the same patient.
- Participants in Track 2 receive full reimbursement; those in Track 3 are paid prospectively.
Understanding G9038: Ambulatory Co-Management Code
G9038 enables specialists participating in the MCP model to bill for time spent co-managing a patient’s care with a primary care provider. Unlike other care coordination codes, G9038 does not require the patient’s condition to be life-threatening or at risk of significant decline.
Key Conditions for Billing G9038:
- The patient must be attributed to an MCP participant in Track 3.
- Claims must be at least 30 days apart for the same patient, by the same specialty.
- Billable up to three times per year per patient.
Closing the Gap in Care Coordination
The introduction of HCPCS Codes G9037 & G9038 provides PCPs and specialists with a structured way to document, bill, and be reimbursed for interprofessional collaboration. These codes enhance communication, improve patient outcomes, and reduce healthcare costs by enabling timely, well-coordinated specialty care.
For full details on MCP model participation and billing requirements, visit the Resources section.
HCPCS Codes G9037 & G9038: Essential for Comprehensive Primary Care
HCPCS Codes G9037 and G9038 are HCPCS Level II codes used in medical coding for reporting services related to comprehensive primary care. These specific codes, HCPCS Codes G9037 & G9038, are primarily used by healthcare providers participating in value-based care models to track and report patient care coordination and management activities.
- G9037: This code represents comprehensive primary care services provided by a physician or other qualified healthcare professional, focusing on patient-centered care, preventive services, and chronic disease management.
- G9038: This code is similar but is used specifically for non-physician healthcare providers offering comprehensive primary care services.
G9037 and G9038 are codes are commonly used in medical coding companies that specialize in family medicine, internal medicine, geriatrics, and primary care. They are critical for ensuring proper reimbursement in accountable care organizations (ACOs) and patient-centered medical homes (PCMHs).
Accurate usage of these codes helps improve care coordination and aligns with Medicare’s focus on quality-based payment models.