In Brief: How did the G2211 code impact physician production and industry benchmarks?
When the Centers for Medicare & Medicaid Services (CMS) implemented add-on CPT code G2211 effective January 1, 2024, the intent was clear: to better capture the resource costs associated with longitudinal care relationships between clinicians and patients. As an add-on code worth 0.33 work relative value units (WRVUs), G2211 could be billed alongside office/outpatient evaluation and management (E&M) codes (99201 to 99205 and 99211 to 99215) and—importantly—by any clinician, not just those in primary care.
The Promise and the Projection
At launch, CMS projected that G2211 would be billed in 38% to 54% of eligible new and established visits, depending on provider behavior and patient mix. The aim was to recognize the cognitive effort and continuity of care involved, regardless of whether the clinician already had an established relationship with the patient.
To understand the potential implications, ECG modeled what would happen if every physician billed G2211 at the projected rates of 38% and 54%.
The result? A meaningful increase in WRVUs across nearly every specialty (i.e., hospital-based specialties experienced a nominal impact). However, that increase brought more complexity than clarity. The projected impact on WRVUs across specialty categories is summarized below. As illustrated, the largest increase was within the primary care specialty category, ranging from approximately 5% to 6%.1
Projected Change to 2025 WRVU Benchmarks Medians
Adulted Survey Weighted Medians
A Mixed Picture of Adoption
While Medicare was quick to reimburse the code, as expected, commercial payers lagged. This created a dilemma for health systems and medical groups: Should they adopt the code and allow physicians to bill it when revenue is guaranteed from only one major payer?
For groups operating on a fixed salary model, the decision was relatively simple. Any G2211 revenue was net-new income without an offsetting expense. But for WRVU-based compensation models, the question became more complicated: Would the reimbursement justify the increased compensation outlay?
Some groups held back entirely from billing the code, not wanting to deal with recalibrating compensation plans. Others billed the code but did not factor it into WRVU-based compensation. As a result, early utilization has fallen well short of Medicare’s expectations.
Early Utilization: Reality Versus Projection
We determined the actual utilization of G2211 by evaluating the CPT data from over 20,000 physicians practicing within adult specialties in our 2025 Physician and APP Compensation Survey, providing a clearer picture of the impact of G2211 utilization on benchmarks.
- Across this subset of physicians, G2211 was appended to only 5.2% of eligible E&M codes, which is far below CMS’s estimated range of 38% to 54%. Furthermore, only 36% of physicians billed the code, while 64% did not.
- Among physicians who billed G2211, it was billed alongside an average of 14.5% of their total 99202 to 99215 volume.
- By specialty, early adoption appears to hover in the low single digits, with primary care and select medical subspecialties having the highest early adoption. The actual impact on WRVU benchmark medians was less than 0.5% across all specialties. Primary care and medical subspecialties had the highest impact of 1.1% and 0.6%, respectively.
Consequently, compensation per WRVU median values are less than 0.5% lower than they would be without the implementation of G2211.
WRVUs and Compensation per WRVU: Impact on G2211
Adulted Survey Weighted Medians
In our release of 2025 benchmark data (reflecting 2024 actuals), we provide:
- Adoption rates by specialty category.
- The impact of G2211 on median WRVUs.
- Differences in median compensation-to-WRVU ratios with and without G2211.
This data helps provider organizations understand whether and how to adjust their compensation strategies moving forward.
What’s Next: Advanced Primary Care Model (APCM) Add-On Codes in 2025
CMS has announced three new add-on codes under the APCM umbrella for the 2025 MPFS. These codes aim to further reflect the time, intensity, and complexity of primary care services, essentially expanding on the concept behind G2211.
With the introduction of these APCM codes, some existing codes may be eliminated or folded into the new structure. As with G2211, CMS will release estimates on expected utilization and payment impacts.
ECG will repeat the G2211-style analysis next year to assess how these new codes affect WRVUs and compensation benchmarks.
Our Take
For many medical groups, G2211 served as a test case for how operational complexity, payer variation, and compensation models intersect. Its underwhelming early adoption underscores the challenges of aligning reimbursement reform with compensation structures.
As Medicare continues to introduce new codes that reflect the increasing complexity and continuity of patient care, organizations must become more adept at evaluating the financial and compensation implications of these changes. While transitioning to the most current MPFS ensures alignment with contemporary reimbursement policy, groups should be deliberate in how they calculate WRVUs, particularly when these values are tied to compensation or performance incentives. To maintain alignment with published compensation benchmarks, which are typically based on prior-year MPFS values, it may be prudent to adopt a one-year lag in WRVU calculations. This approach helps ensure methodological consistency and comparability with survey-based benchmark data.
Yet as Medicare continues to roll out new codes that reflect the evolving nature of patient care, organizations will need to become more agile by analyzing the data, understanding the financial and compensation implications, and ultimately deciding how to respond.
