Medicare physician fee schedule proposal includes changes to G2211, other codes

The Centers for Medicare & Medicaid Services’ (CMS) proposed rule for the 2027 Medicare Physician Fee Schedule (MPFS) includes a number of proposals germane to family medicine, including changes to visit complexity add-on code G2211 and reductions in the conversion factor, the amount Medicare pays per relative value unit (RVU).

Conversion factor proposal

To comply with current law, CMS is again proposing two conversion factors — one for physicians who are qualifying participants (QP) in an advanced alternative payment model and another for those who are not. The proposed conversion factor for QPs next year is $33.1693 (a decrease of $0.40, or 1.19%). For non-QPs it is $32.84 (a decrease of $0.56, or 1.68%). The conversion factor changes are based on the same factors that caused a pay cut in 2026:

• The expiration of a one-time 2.5% increase that was included in the Working Families Tax Cut legislation, previously called the “One Big Beautiful Bill Act” (H.R. 1).
• A 0.53% budget-neutrality adjustment. This is meant to offset the cumulative impact of several proposals projected to decrease payments (by law, CMS must propose budget neutrality offsets if other policies are projected to increase or decrease expenditures by more than $20 million). These proposed policies include changes to RVUs for specific services and changes to modifier 25 that would reduce payment for visits that combine evaluation and management (E/M) with procedures that have a global period.
• A 0.75% increase for QPs and a 0.25% increase for non-QPs.

New code and payment for G2211

CMS proposes to replace HCPCS code G2211 with a modifier (currently “MOD1”) paid at 16% of its corresponding E/M code, rather than G2211’s current flat rate. CMS also proposes to establish a similar modifier (currently “MOD2”) for accountable care organizations paid at 32% of its corresponding E/M code.

E/M with procedure codes that have a global period

CMS has long reduced payment when physicians report multiple surgical procedures on the same patient in the same day, under the assumption that the overlap of resources required creates efficiency. Now, CMS proposes to expand this policy and reduce payment when a physician or their colleague in the same group practice reports a separately identifiable office/outpatient E/M visit on the same day as a procedure with a 0-, 10-, or 90-day global period. In these cases, CMS will pay the more expensive service (either the procedure or the E/M) at 100% and pay all other procedure or E/M codes at 50%.

Expansion of primary care exception

CMS proposes to allow qualified primary care centers to provide all levels of office/outpatient evaluation and management (E/M) services under supervision of a teaching physician without that physician being physically present. Under current CMS policy, residents may only provide E/M levels 1-3 without the teaching physician physically present. The new policy would expand that to all E/M levels when the teaching physician is immediately available (i.e., in the same building) and believes the care is clinically appropriate.

Maternity care

CMS proposes to adopt CPT code revisions that unbundle the maternity global packages and restructure how to report maternity services. However, CMS is also seeking comments on whether they should create G-codes that would maintain the current bundled coding and payment structure for maternity services and use those instead of the new CPT codes.

Shared medical appointments (SMAs)

CMS proposes to create a G-code specifically for SMAs, or group visits. It would apply to 60-minute sessions for up to 10 patients, either in-person or via telehealth.

All patients in the SMA would have to have received care within the previous 12 months from the physician or qualified health care professional (QHP) conducting the SMA or from another physician or QHP of the same specialty and subspecialty in the same group.

Medicare Shared Savings Program (MSSP) and Quality Payment Program (QPP)

CMS made several proposals to encourage participation in the MSSP, including increasing the savings rate for BASIC Level E from 50% to 60% and refining the benchmarking methodology. CMS did not propose any major changes in the QPP, but is proposing to phase out the traditional Merit-based Incentive Payment System by 2029.

CMS also issued several requests for information (RFIs) in this year’s proposed rule. These include an RFI on redesigning primary care and an RFI examining the role of the CPT coding system in physician payment policy.

The MPFS proposed rule was published in the Federal Register on July 16, and comments are due by Sept. 14. For additional information, please see the related CMS news release, MPFS fact sheet, QPP fact sheet, and MSSP fact sheet. The American Academy of Family Physicians developed an executive summary that provides a more comprehensive look at the proposals relevant to primary care.

— Erin Solis, Manager, Practice & Payment at the American Academy of Family Physicians