CMS wants to retire G2211's flat add-on and pay a percentage of the visit instead — 16% for everyone, 32% if you're in an ACO. Same note, same patient, different contract. Here are all 24.5 million real 2024 add-on claims, and the break-even line you can drag.
G2211 is the office-visit complexity add-on. You append it to an established-patient E/M when you're the clinician carrying that person's care over time, and Medicare pays you a flat amount for it — about $16, the same $16 whether the visit underneath was a 99212 or a 99215.
For CY 2027 CMS proposes turning it into a modifier on the base code instead. In the agency's own words:
A flat fee and a percentage are not the same instrument. A flat fee is indifferent to what you did. A percentage is a multiplier on the thing you already got paid for — so it rewards whatever the base code rewards, and it moves when the base code moves. The question “sixteen percent of what?” is the entire policy.
Each dot is one specialty. Horizontal position is the average Medicare-allowed amount of that specialty's office E/M visits — the base the percentage would multiply. Vertical position is how often they attach G2211 at all. Dot area is 2024 add-on volume.
At the proposed 16%, the flat $16 turns out to have been underpaying almost everyone. Nudge the slider down toward 14% and the line marches right; nudge it to 32% and it falls off the left edge of the chart entirely. The specialties on the wrong side of the line at 16% are the ones whose average office visit is cheap — dermatology and podiatry, where the E/M is often a short established-patient visit attached to a procedure.
The interesting number isn't 16%. It's the distance between 16% and 32%. Two clinicians, same patient, same note, same complexity attestation — and the one whose employer signed a Shared Savings Program agreement gets paid twice the add-on. Under the proposal MOD2 is voluntary and billable for all beneficiaries the ACO participant sees, not only assigned ones. That makes it less a payment for longitudinal work than a payment for a contract you may have signed years ago, for reasons that had nothing to do with this visit.
1. Counting specialties is not counting dollars. Turn off “size dots by add-on volume” and 45 equal circles appear, each looking like an equal stakeholder. They are not. Family Practice, Internal Medicine and Nurse Practitioner alone are half of all G2211 volume. The dozen dots at the bottom of the chart together carry less than 2% of the money. Drag the “min billers” slider and watch the dot count collapse while the dollar total barely moves — that gap is the whole argument for weighting.
2. The base I'm multiplying is the wrong base. This simulation multiplies each specialty's average office E/M allowed amount. But G2211 isn't attached to an average visit — it's attached to the specific visits where a clinician asserts longitudinal responsibility, which skew toward established-patient 99213/99214. If those visits are cheaper than the specialty's overall mix, every gain here is overstated. CMS has the claim-level pairing. The public file does not.
3. Nothing here is budget-neutral yet. A +15% swing in add-on dollars doesn't appear from nowhere; under PFS budget neutrality it comes back out of the conversion factor, which lands on everyone including the specialties that never bill G2211. The chart shows the redistribution, not the net.
And the suppression floor: CMS drops any provider-code combination with fewer than 11 beneficiaries. Low-volume specialties are systematically undercounted here, and there's no flag for it — the row is simply absent.