Surgeon Experts Question Evidence for Proposed Complexity Payment Changes

Proposed changes to the Centers for Medicare & Medicaid Services (CMS) G2211 visit complexity payment raise questions about what the policy pays for and whether another revision is justified, according to a new Health Affairs perspective, “Changing G2211 Again: What Problem Is CMS Trying To Solve?”

The authors are Christopher P. Childers, MD, PhD, a member of the ACS General Surgery Coding and Reimbursement Committee; Don J. Selzer, MD, FACS, an ACS Regent and Vice-Chair of the committee; and Thomas C. Tsai, MD, MPH, FACS, Medical Director for Health Policy Research in the ACS Division of Advocacy and Health Policy.

For 2027, CMS proposes replacing G2211’s fixed add-on payment with percentage-based modifiers: a 16% increase for eligible evaluation and management (E/M) services and 32% for qualifying clinicians participating in accountable care organizations.

The authors question the evidence supporting this shift. Although CMS cites simpler claims processing and better recognition of complexity, they note that neither rationale is supported by evidence demonstrating improved measurement, accuracy, or patient care. They also ask what distinct work G2211 recognizes beyond existing E/M valuations and care management payments.

Their analysis found G2211 was billed with approximately 11% of eligible visits in 2024, compared with CMS’s initial projection of 38%. Applying the proposed 16% modifier to those use patterns would have increased spending by approximately $87 million, predominantly benefiting office-based clinicians.

For surgeons, the question extends beyond G2211: how can Medicare consistently identify and pay for complex care? The authors point to the limited additional payment associated with modifier 22, due in part to inconsistent recognition and higher denial rates, as well as the rejection of a proposed modifier for the complexity of operating on patients with obesity. They argue that changing G2211’s payment mechanism may leave the underlying challenge of measuring and valuing complexity unresolved.

With the final 2027 Medicare Physician Fee Schedule rule expected around November 1, the authors encourage CMS to evaluate the effects and unintended consequences of existing policies before making another structural change.

The commentary complements recent ACS research examining the evidence behind other proposed MPFS changes (see recent Health Policy Briefs, Part 1 and Part 2).