By Ishani Ganguli, M.D.
August 28, 2026
When Beatrice—not her real name—arrived at my clinic following a fall, the scope of our appointment immediately expanded beyond the physical trauma. My role as her primary care physician (PCP) was not merely to assess her injuries, but to weave together the disparate threads of her health. I reviewed security footage of her fall on her smartphone, performed a head-to-toe clinical assessment, and carefully calibrated a pain management regimen that would not exacerbate her chronic gastritis.
But our visit did not end there. I addressed her renewed anxiety, titrated her thyroid medication, provided an overdue vaccination, and coordinated a follow-up visit with our clinic’s nursing staff. This comprehensive, longitudinal, and relationship-based care is the bedrock of medicine. As of 2024, Medicare has attempted to recognize this labor by adding a specific line item to the physician’s bill: the G2211 code. However, two years into this experiment, we must ask: Is a $16 supplement enough to save a crumbling system, or are we merely applying a bandage to a systemic fracture?
The Anatomy of the G2211 Code
The G2211 code was introduced by the Centers for Medicare & Medicaid Services (CMS) as a well-intentioned, if modest, effort to provide additional compensation for the "cognitive work" inherent in primary care. By allowing physicians to bill an additional $16 per visit for complex, ongoing care, Medicare aimed to acknowledge the reality that a doctor’s value is not found solely in procedures, but in the time spent managing chronic conditions and navigating complex patient histories.
From a policy perspective, the code was designed to counteract the long-standing bias of the Medicare Physician Fee Schedule. For decades, this schedule has been heavily influenced by specialty-predominant committees, which historically set higher reimbursement rates for procedural interventions—such as cataract surgeries or dermatological biopsies—than for the high-touch, cognitive work performed by primary care physicians.
A Chronology of Payment Distortion
To understand why the G2211 code was deemed necessary, one must look at the historical trajectory of American health care finance.
The Era of "Fee-for-Service" Dominance
The U.S. health care system has long operated on a "fee-for-service" model. Under this paradigm, doctors are incentivized to maximize volume. Each "unit" of service—a procedure or a brief exam—is assigned a specific dollar amount. This structure creates a perverse incentive: it rewards high-intensity interventions while effectively penalizing the time-intensive, behind-the-scenes work that defines high-quality primary care.
The "Between-Visit" Gap
The most critical work of a primary care physician often happens when the patient is not in the room. This includes:
- Navigating ambiguous symptoms via email or telehealth portals.
- Coaching patients through complex lifestyle modifications for conditions like acid reflux or hypertension.
- De-prescribing unnecessary medications that have accumulated through years of fragmented, multi-specialty care.
These activities are essential for better health outcomes and increased longevity, yet they have historically gone uncompensated. As a result, the U.S. primary care system has become increasingly underfinanced and understaffed, leading to a decline in access and, paradoxically, higher overall costs compared to other developed nations.
The 2024 Implementation and 2026 Confirmation
In 2024, after years of advocacy from primary care organizations, CMS implemented G2211. Despite initial opposition from various surgical and specialty societies—who feared that the redistribution of limited Medicare funds would result in a "zero-sum game" where their own reimbursements might shrink—the code was launched. In August 2026, CMS confirmed that the code would remain a permanent feature of the Physician Fee Schedule, signaling a commitment to at least attempting to address the primary care deficit.
Supporting Data: Is the Code Working?
As a health services researcher, I have closely scrutinized the uptake and application of G2211. Our research, published recently in JAMA, reveals a complicated picture.
High Volume, Misaligned Intent
In its first year, the code was billed approximately 26 million times. Statistically, this represents an impressive adoption rate, with roughly one in four doctors billing Medicare utilizing the code. However, the distribution of who is using the code raises significant questions.
While the code was intended to support longitudinal primary care, our data indicates that 43% of the codes were billed by specialists, compared to 40% by primary care physicians. We observed that many specialists utilized G2211 for routine visits—such as follow-ups for acid reflux or mild glaucoma—which do not inherently fit the profile of the "complex, longitudinal" care the code was designed to support.
The Patient Perspective: Transparency vs. Complexity
For patients, the G2211 code represents a confusing addition to their Explanation of Benefits (EOB). While the out-of-pocket cost for a patient is typically modest—often around $3—the addition of this fee has led to public frustration. High-profile commentary in outlets like The Wall Street Journal has highlighted how this surcharge can feel like "nickel-and-diming," particularly when the billing justification is obscured by bureaucratic jargon.
Implications for the Future of Primary Care
The G2211 code is, at best, a stopgap. The fundamental challenge remains: our payment system is still fundamentally built around the visit, while the health of our patients is built around the relationship.
The Problem of "Visit-Chasing"
By tying the additional payment to a physical or virtual visit, the G2211 code inadvertently reinforces the "fee-for-service" trap. It incentivizes clinicians to keep patients coming back to the office to capture the billing code, rather than fostering a model that rewards better health outcomes through more efficient, non-visit-based care. Some colleagues have even expressed a sense of "moral injury," noting that they must click an extra box in an electronic health record to justify a level of care that has always been the standard for their practice.
The Rise of Advanced Primary Care Management (APCM)
Recognizing these limitations, CMS began introducing Advanced Primary Care Management (APCM) codes in January 2025. Unlike the visit-dependent G2211, APCM codes translate into larger, monthly per-patient payments. This shift represents a move toward "capitation-lite" models, which provide a set budget to cover the range of team members and services necessary to manage a patient’s health, regardless of how many times that patient walks through the clinic door.
CMS has recently announced plans to explore even more ambitious versions of these per-patient payments by 2027. This shift is essential. If we are to move toward a system that provides a trusted medical advisor for every American, we must transition away from paying for "encounters" and toward paying for "health."
Conclusion: A Call for Structural Reform
The G2211 code serves as a diagnostic marker for the state of American primary care: it shows that we know there is a problem, but we are still struggling to find the right treatment.
Primary care is the foundation of a high-functioning health system, yet it remains the most undervalued sector in American medicine. While the G2211 code is an acknowledgement of the vital, complex work done by primary care physicians, it is ultimately a transactional solution to a relational problem. As we look toward the 2027 Medicare reforms, the goal must be clear: we need a system that honors the time, the expertise, and the long-term commitment that doctors like myself provide to patients like Beatrice. Until we move beyond the visit-based, fee-for-service paradigm, we will continue to struggle with a system that is, at its core, understaffed, underfinanced, and disconnected from the needs of the people it serves.
Ishani Ganguli, M.D., is an associate professor of medicine, a health services researcher, and an internal medicine primary care physician at Harvard Medical School and Brigham and Women’s Hospital. She is a member of the National Academies of Sciences, Engineering, and Medicine Standing Committee on Primary Care. This article represents her own views and not necessarily those of the committee. This work was supported by a grant from The Commonwealth Fund.
