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JotPsych Notes
JotPsych Notes: from the Medical Group Management Association conference

4 steps to see whether Medicare's G2211 proposal raises your pay

G2211 would become a modifier worth 16 percent of the visit's payment. Visits at 99214 and 99215 would pay more, and visits at 99212 and 99213 would pay less.

You add G2211 to your Medicare follow-ups, and it pays the same at every level. Under Medicare's 2027 proposal, the level you bill would set the add-on's amount. Your mix of levels decides whether you gain or lose.

Medicare's complexity add-on per follow-up visit: G2211 in 2026 and the proposed modifier in 2027, by visit level
dollars per visit, a physician's national office rates before the geographic adjustment
$17
$9
$15
$21
$30
G2211, any level, 2026
Modifier on a 99212
Modifier on a 99213
Modifier on a 99214
Modifier on a 99215

Medicare's 2026 rate file and its proposed 2027 addendum, with the modifier at 16 percent of the visit's payment. Purple bars would pay less than G2211, and dark blue bars would pay more.

Four steps to price your follow-ups

  1. Count your 2025 G2211 follow-ups by level. Sort them into 99212, 99213, 99214, and 99215.
  2. Price your mix both ways. For 2026, multiply your G2211 count by the flat $17 in the bar chart. For 2027, multiply each level's count by its proposed modifier in the bar chart. Compare the totals. Nurse practitioners get 85 percent of each amount.
  3. Check ten notes against the level billed. The level on each claim would set two payments: the visit's and the modifier's. You'd lose the difference between the two levels on both payments if you billed a 99213 for a note that supports a 99214. You'd risk both payments if you billed above the note.
  4. Run step 2 again with the final rule's amounts. The Centers for Medicare & Medicaid Services (CMS) has to set the 2027 rates before November 1, under federal law. Don't plan on the proposed amounts before then.

Practices in a Medicare Shared Savings Program accountable care organization (ACO) would bill a second modifier, worth 32 percent of the visit's payment, under the proposed rule. So would practices in CMS's new Long-term Enhanced ACO Design (LEAD) model, the rule says. Price your mix at that rate if you're in either program.

A 99214 follow-up with the complexity add-on, as billed in 2026 and as proposed for 2027
a physician's national office rates before the geographic adjustment; CMS rate files
2026 claim
99214 office visit$136
G2211 add-on$17
Visit total$153
2027 claim, proposed
99214 office visit$133
Modifier, 16 percent of the visit's payment$21
Visit total$154

Rates from CMS's 2026 rate file and its proposed 2027 addendum. On a 99214 the modifier pays a little more than G2211, while the visit itself pays a little less.

Your 99212 follow-ups would lose the most. At a physician's national office rate before the geographic adjustment, a 99212 visit with the modifier would pay $67 in 2027, down from $77 with G2211 in 2026.

In the proposed rule, CMS writes that a flat rate "does not reflect the variation in work" across visit levels. Government affairs staff at the Medical Group Management Association flagged the change for members.

JotAudit checks your visit code against the note before you sign and shows Codes Supported or the code it recommends.

See JotAudit
Sources:
  1. Madison Hynes, MPP, and James Haynes, JD, associate directors of government affairs at the Medical Group Management Association (MGMA), “MGMA Government Affairs: 2026 Washington Update”, MGMA 2026 Annual Conference, San Antonio, September 27, 2026. Slide 9, “Changing from add-on code to modifier.”
  2. Centers for Medicare & Medicaid Services, 2027 Physician Fee Schedule proposed rule (CMS-1848-P), 91 Federal Register 43842, July 16, 2026: the modifier and its valuation at 43899, and the 32 percent modifier at 43901.
  3. CMS, 2026 National Physician Fee Schedule Relative Value File, October release (RVU26D), with the 2026 conversion factor of $33.4009 for clinicians outside advanced payment models.
  4. CMS, Addendum B to the 2027 Physician Fee Schedule proposed rule, updated July 21, 2026, with the proposed 2027 conversion factor of $32.8409 from the rule at 44241.
  5. CMS, Medicare & Mental Health Coverage (MLN1986542), March 2026: the payment for each type of clinician, pages 13 to 24; read October 2, 2026.
  6. United States Code, title 42, section 1395w-4 (Social Security Act section 1848), subsection (b)(1): the fee schedule is set before November 1 of the year before.