Primary care physicians earn approximately $80,000 less annually in Medicare reimbursement than subspecialists, despite managing high cognitive loads and a broad scope of responsibility. This discrepancy reflects not simpler work, but the historical failure of reimbursement models to account for longitudinal cognitive labor.
A central driver of this gap is the coordination burden. Primary care physicians routinely manage care across dozens of specialists and settings for their Medicare panels. This non‑procedural work — medication oversight, longitudinal planning, and integration of fragmented recommendations — has traditionally been invisible to reimbursement. CMS introduced HCPCS add‑on code G2211 in January 2024 to begin compensating for the “visit complexity inherent to evaluation and management associated with medical care services.”
G2211 does not measure how sick a patient is. Rather, it captures the complexity created by ongoing responsibility.
Eligibility depends on two elements: the visit itself (acute or chronic) and the longitudinal relationship in which it occurs. CMS describes two qualifying pathways. The first applies when the clinician serves as the continuing focal point for all needed health services. The second applies when the clinician manages a single serious or complex condition requiring ongoing care, such as HIV, sickle cell disease, or severe mental illness.
As the AAFP has noted, the complexity is not the diagnosis alone, but the cognitive load of continued responsibility.
In practical terms, G2211 is appropriate for patients with multiple chronic conditions, individuals with a single complex condition requiring lifelong therapy, frail or elderly patients requiring intensive coordination, and patients with significant social determinants of health that complicate care delivery. It should not be billed for isolated acute issues, procedure‑only encounters, urgent care or cross‑coverage visits, or one‑time consultations such as preoperative clearance.
Consider a common scenario: a 65‑year‑old established patient presents with sinus pressure. During the visit, hypertension and hyperlipidemia are reviewed, chronic medications reconciled, and upcoming laboratory monitoring discussed. In this case, the qualifying factor is not the sinus complaint, but the longitudinal relationship and ongoing responsibility. G2211 is appropriate.
Recent policy expansions have strengthened the utility of the code. Beginning January 1, 2025, Medicare allows payment of G2211 when billed with Modifier 25 if the Evaluation and Management (E/M) service is significant and separately identifiable, including when paired with preventive services such as Annual Wellness Visits. Expansion to home and residence E/M codes is planned for 2026.
While G2211 will not correct decades of payment imbalance or administrative burden, it represents a meaningful acknowledgment that continuity, coordination, and cognitive labor are foundational to high‑quality primary care. Appropriate use aligns reimbursement more closely with the work required to prevent downstream utilization and support high‑need patient populations.
When have you used G2211? Share in the comments.
Dr. Muhammad Kashif Minhaj is a dual board-certified internal medicine physician and obesity medicine specialist in Tomball, Texas. He focuses on primary care, evidence-based medicine, and elevating the often under-recognized cognitive work of longitudinal care.
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