What Medicare's add-on code G2211 means for your practice

The code G2211 is a Medicare-specific add-on code to office and other outpatient (O/O) services designed to address the complexity inherent in office and outpatient evaluation and management (E/M) services. CMS created this code to better reflect the resources and additional costs associated with providing comprehensive, longitudinal primary care, such as time, intensity, and practice expense.

ACP has long supported the implementation of G2211, as discussed in the Practice Rx column in the May 2023 ACP Internist, and is pleased that the proposed 2024 Medicare Physician Fee Schedule (PFS) includes refinements to its use. For example, CMS has proposed that the new code not be billed with a modifier that already captures complexity in the valuation. Furthermore, the proposed adjustment to G2211's utilization estimates will be beneficial, as inflated estimates result in adverse budget neutrality adjustments for all specialties.

The proposed rule estimates that G2211 will be billed with 38% of all O/O E/M visits initially. These revised utilization assumptions were calculated by considering the uptake of new codes in prior years and the O/O E/M billing patterns of all specialties. CMS estimates that G2211 will be billed with 54% of all O/O E/M visits once it is fully adopted.

CMS is seeking comment on these utilization assumptions and the application of the proposed policy, which would take effect Jan. 1, 2024. In a joint letter with the American Academy of Family Physicians (AAFP), ACP highlighted that implementing G2211 will do the following:

• Help promote beneficiaries' timely access to primary care and other continuous services that promote better health care outcomes and help reduce spending by strengthening the patient-physician relationship. The new code directly supports physicians' ability to foster longitudinal relationships, address unmet social needs, and coordinate patient care across the team.
• Advance more appropriate payments for primary care and other longitudinal, continuous care under the Medicare Physician Fee Schedule. G2211 is not duplicative of other codes and fills a gap left by the current Medicare PFS coding and billing structure that is straining physician practices. Financial struggles due to gaps in current payment codes harm patients, as practices are forced to shorten office visits or accept fewer Medicare beneficiaries.
• Promote fair and accurate Medicare payments. G2211 will help sustain primary care and other physician practices that Medicare beneficiaries rely on, close compensation disparities, and bolster patient access to a physician workforce that better meets the needs of our aging population.

ACP's Legislative Action Center (LAC) has created an action alert for ACP members to email both CMS and members of Congress and support the 2024 implementation of the Medicare visit complexity code G2211. Implementation of G2211 will allow physicians to account for services such as chronic disease management tracking, review of consultative or diagnostic reports, medication monitoring, safety outside of patient visits, and physician input at assisted living or nursing homes. A