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September 29, 2023

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Letter to Congress: Billing Code G2211 is Critical For Senior Care

Dear Speaker McCarthy, Leader Jefferies, Leader Schumer, and Leader McConnell:

On behalf of Primary Care for America, we write to strongly urge Congress to support the Centers for Medicare & Medicaid Services’ (CMS’) proposal to implement a Medicare billing code, known as G2211, in 2024 as implementation of this this add-on code will improve Medicare beneficiaries’ access to high- quality, patient-centered care. Our diverse collection of organizations represent clinicians, products, and clinics caring for infants and children; adults and seniors in the Medicaid, Medicare, and commercial markets; as well as the uninsured in every county across the nation. We recognize the undeniable importance of a well-functioning primary care infrastructure to the health of our nation and implementation of G2211 represents an important step in service to that goal.

Primary care is the only element in our healthcare system where an increased supply is associated with better health outcomes and longer lives, yet our financing system is not constructed in a way to appropriately recognize the inherent value of continuous, comprehensive care.i,ii,iii The G2211 add-on code is designed to capture the time, intensity, and practice expenses expended to meaningfully establish relationships with patients and address most of their health care needs with consistency and continuity – many of whom have multiple complicated health issues. These ongoing, trusted relationships lead to fewer hospitalizations and unnecessary complications and lower costs.iv The true benefit of primary care is in prevention and wellness and this code captures the value associated with promoting preventive care, effectively managing complex conditions, and coordinating care across the delivery system.

CMS finalized the G2211 code in the 2021 Medicare Physician Fee Schedule but implementation was paused by Congress in late 2020 with the intent of going into effect in 2024. Our organizations urge Congress to allow the G2211 code be fully implemented by CMS in 2024 as intended to ensure that our nation’s seniors have access to high-quality, comprehensive, patient-centered care.

It is well-documented that our current fee-for-service financing system fails to capture the true benefit of primary care to the delivery system by rewarding volume and disease acuity.v This system puts those clinicians and entities committed to whole-person health and prevention on a collision path and without the needed resources to adequately address the needs of their patients. This results in shorter office visits, longer wait times, and limits on how many Medicare beneficiaries practices are equipped to accept. This is antithetical to the goals of providing overall improved population health at a lower cost. Our nation should be doing all we can to support the provision of high-quality, comprehensive care and make it accessible for everyone. Implementation of G2211 is an important step in the right direction.

Our organizations look forward to partnering with you to bolster and sustain primary care to ensure the health and well-being of our communities.


Primary Care for America (PCfA) is a collaboration focused on demonstrating the value of primary care, the need for increased primary care investment, and the importance of innovation in primary care delivery and payment models. PCfA is comprised of a diverse group of key partners in the American health care industry: agilon health, Aledade, American Academy of Family Physicians, American Academy of Pediatrics, American College of Physicians, Catalyst Health Network, Elation Health, Everside Health, MDVIP, National Association of Community Health Centers and VillageMD. For more information about Primary Care for America, visit

i Baker R, Freeman GK, Haggerty JL, Bankart MJ, Nockels KH. Primary medical care continuity and patient mortality: a systematic review. Br J Gen Pract. 2020 Aug 27;70(698):e600-e611. doi: 10.3399/bjgp20X712289. PMID: 32784220; PMCID: PMC7425204.

ii Starfield B, Shi L, Macinko J. Contribution of primary care to health systems and health. Milbank Q. 2005;83(3):457-502. doi: 10.1111/j.1468-0009.2005.00409.x. PMID: 16202000; PMCID: PMC2690145.

iii Basu S, Berkowitz SA, Phillips RL, Bitton A, Landon BE, Phillips RS. Association of Primary Care Physician Supply With Population Mortality in the United States, 2005-2015. JAMA Intern Med. 2019 Apr 1;179(4):506-514. doi: 10.1001/jamainternmed.2018.7624. PMID: 30776056; PMCID: PMC6450307.

iv Bazemore A, Petterson S, Peterson LE, Bruno R, Chung Y, Phillips RL Jr. Higher Primary Care Physician Continuity is Associated With Lower Costs and Hospitalizations. Ann Fam Med. 2018 Nov;16(6):492-497. doi: 10.1370/afm.2308. PMID: 30420363; PMCID: PMC6231930.

v National Academies of Sciences, Engineering, and Medicine. 2021. Implementing High-Quality Primary Care: Rebuilding the Foundation of Health Care. Washington, DC: The National Academies Press.