You should be billing G2211 in heavy volume, per CMS

Who remembers G2211?

Starting in 2024 this CPT code took the mid-revenue cycle by storm. Despite paying very little ($16.04) it was intended to be used in quantity.

It has been.

A new study by the Journal of the AMA found that its first year of full use, calendar year 2024, G2211 was billed 26 million times across 10.6 million patients, generating some $394 million.

Here is the code descriptor (pardon the run-on sentence, that’s CPT, not me):

Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition. (Add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established).

If you read between the long lines, G2211 is intended to help compensate primary care providers (PCPs) for additional cognitive burden managing complex patients with the likes of hypertension, diabetes, or polycystic ovary syndrome. PCPs are the unsung heroes of healthcare and G2211 is supposed to come to their rescue.

If for example a patient has a cardiologist, nephrologist, podiatrist, urologist, physical therapist, gastroenterologist, and the PCP is managing all the complex coordination between specialties, he or she should report G2211.

It has been used, but one problem per the study is that it’s being used more often by specialists—which wasn’t necessarily CMS’ intent.

An article from Medscape (see link below) offers a summary of how even well-intended balance measures can result in unintended consequences. From the article:

• Specialist physicians, including urologists, nephrologists,endocrinologists and rheumatologists, billed 43% of the 26 million G2211 codes in 2024
• PCP billed 39.7% of the codes
• Both are lower than CMS’ prediction of G2211 billed with 54% of visits

That last bullet is critical. CMS wants and expects you to use the code, often.

I’ve included an article from the Norwood website that includes some best practices. A few pointers from that article:

• G2211 is an add-on code that may be reported with new and established patient office/outpatient E/M services
• It is intended to reimburse for the increased resources associated with the complexity of care and cognitive load required by providers who furnish consistent and continuous services for a patient’s overall healthcare or that of a single serious or complex condition. (e.g., a family medicine PCP managing multiple conditions over time, an endocrinologist managing care for type 1 diabetes with complications, an oncologist managing care for cancer, etc.)
• It is not limited by specialty.
• It was added to the CMS Approved Telehealth services list.
• The code is not tied to clinical conditions but rather the overarching “longitudinal” relationship between provider and patient.

As of 2026, G2211 may also be reported with home or residence E/M services (CPT codes 99341-99350).

Are you using it in volume? Have you had any issues with adoption?

 References

• Medscape, “Docs Land Nearly $400 Million in First Year of Controversial Medicare Billing Code”: https://www.medscape.com/viewarticle/docs-land-nearly-400-million-first-year-controversial-2026a10006e8
• Norwood, “OM(G2211)! New HCPCS code leaves mid-revenue cycle professionals with lingering uncertainty”: https://www.norwood.com/omg2211-new-hcpcs-code-leaves-mid-revenue-cycle-professionals-with-lingering-uncertainty/