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Physicians paid for G2211 twice. Most never bill it.

Michael Duben, MD
Physician Finance
September 23, 2026
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In 2024, Medicare cut every physician’s rates about 2 percent to fund a code that 3 out of 4 of them never billed. The cut was automatic. The code has to be claimed by hand.

The code is G2211. CMS calls it a visit complexity add-on. In plain words, it pays for office visits where you are the patient’s ongoing doctor, either as the continuing focal point for all their care or for a single serious or complex condition. It goes on top of a 99202 through 99215, any level, any length. Medicare pays about $17 for it. There is no diagnosis requirement and no specialty restriction. CMS says so in its own billing guidance, MLN Matters MM13473. An endocrinologist following thyroid cancer or a nephrologist following kidney disease is the intended use, not a loophole.

The history explains part of the neglect. CMS finalized the code for 2021. Congress blocked it for 3 years over budget neutrality, so from 2021 to 2023 the coding literature described it as unpayable, which it was. A lot of billers learned “don’t bother” and never unlearned it. It became payable on January 1, 2024.

Here is how it was paid for. Medicare’s fee schedule is budget neutral by law. When CMS adds a payment, it lowers the conversion factor, the dollar multiplier on every service every physician bills, to cover the projected cost. For 2024, CMS assumed G2211 would go on 38 percent of office visits and cut the conversion factor to match. The budget neutrality adjustment that year was 2.18 percent, and CMS attributed about 90 percent of it to this 1 code.

Then the code went on 11 percent of visits. In 2025, by CMS’s own claims data, it went on 19 percent. Half of what everyone had already paid for. A 2026 analysis in JAMA of all traditional Medicare claims found that of 855,000 clinicians with at least 1 eligible visit in 2024, 24 percent billed the code at all. The AMA did the arithmetic and asked CMS to restore the excess cut, about $1 billion in 2024 alone, and it carries forward because each year’s conversion factor is built on the last. CMS declined in the 2026 final rule. It said it does not go back and compare actual use to the assumptions it made when a code started.

So physicians paid for this code twice. Once in the rate cut, which nobody could avoid, and again in every eligible visit that went out without it.

I found the code myself. Nobody told me. My first claims went out with modifier 25 attached and were denied. Refiled without it, they paid. About 70 percent of my visits qualify, which comes to about $17,000 a year in a solo endocrine practice. The rest either don’t qualify or carry modifier 25 for a same-day ultrasound or injection, and the code doesn’t pay with it. Commercial plans apparently don’t pay for it in my state (I tried). Medicaid in my state doesn’t. Managed Medicare does, and the secondaries pick up the coinsurance. The money is real, and it arrives only if the physician knows to add the code.

The code was never a secret. CMS announces it in a fee schedule rule over 1,000 pages long, and the Medicare contractor posts a webpage. Nobody’s job is to walk it into the exam room. In an employed group, the physician assumes revenue cycle has it, and revenue cycle sits downstream of the person picking the code. A billing company paid on percentage doesn’t chase a $17 line. A compliance officer sees a descriptor with no diagnosis attached and sees an audit, though I can’t find a public record of Medicare recouping it. The software that now suggests codes still needs a click, and the person clicking is the one who never heard of it.

What qualifies is the relationship, not the visit. Will you see this patient again for this condition, and are you the one managing it? If yes, the code applies. That is nearly every established follow-up in my practice: the diabetic, the thyroid cancer survivor on surveillance, the osteoporosis patient on treatment, the adrenal patient I have followed for 15 years. A new patient counts if you intend to take on the ongoing care. Telehealth counts. What doesn’t qualify is the one-time consult you send back to the primary, and any visit carrying modifier 25 for a same-day procedure, unless the same-day service is a wellness visit, a vaccine, or another preventive service. The Endocrine Society’s guidance is that it doesn’t belong on every claim and the record should show the relationship. One sentence in the note does that.

Now scale it. Take a group of 100 physicians and 40 physician extenders, a mix of primary care and medical specialties. At 90 patients a week each, 48 weeks a year, 30 percent on Medicare, that’s 181,000 Medicare visits a year. CMS priced the rate cut on the code going on 38 percent of them. National claims show 19 percent. At $17.15 a visit, the difference is about $600,000 a year the group has already paid for and is not collecting, and 38 percent is only what CMS assumed. Where a higher share of visits qualifies, and in my practice it does, a lot more is left on the table. Nothing about the visit changes to earn it. Physician extenders can bill it under their own NPI, same rules, and in the national data they use it well below the physician rate.

The fix is an owner and a default. Someone whose name is on it, who sees a monthly count of eligible Medicare visits that went out without it. A charge template that carries the code by default on established Medicare visits, extenders included. The clinician takes it off when the relationship isn’t ongoing. The system takes it off when modifier 25 is on the visit. In a solo practice, the owner is you and the default is a line on your superbill.

The price of forgetting is about to go up. For 2027, CMS proposes deleting G2211 and replacing it with a modifier on the visit code itself, worth 16 percent of the visit. A second modifier, for practitioners in a Medicare ACO, pays 32 percent. Comments closed in September. The final rule usually lands around November 1. Whatever the final numbers, the claim still goes in by hand.

Make the claim as automatic as the cut.

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Michael Duben is a board-certified endocrinologist in solo private practice in Fairfield, Connecticut, and is affiliated with Bridgeport Hospital. He runs both Endocrinology of Fairfield County, a traditional insurance-based practice, and Restore Health, a cash-based functional endocrinology practice. He completed the Institute for Functional Medicine’s training program.

He did his internal medicine residency at Mount Sinai and his endocrinology fellowship at Montefiore/Einstein, and was a clinical instructor in the Department of Endocrinology at Albert Einstein College of Medicine. He has practiced since 2003, with clinical interests in thyroid disease and thyroid cancer, osteoporosis and bone metabolism, parathyroid disease, pituitary disorders, and obesity and metabolic disease. He has prescribed glucagon-like peptide-1 (GLP-1) receptor agonists since the first one reached the market in 2005, and has lectured to practicing physicians on diabetes and thyroid management.

He designed and built the HIPAA-compliant AI-assisted clinical documentation system he uses in daily practice, without formal training in computer science, along with a range of other tools for his patients and his office. He shares updates on LinkedIn.

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