Introduction
CMS just proposed a change that every ACO should take a close look at. It would not take effect until 2027, but it gives us a clear sense of where Medicare payment is headed. CMS wants to pay more for the work practices are doing now, while continuing to hold them accountable for quality and total cost of care.
The visit code you know is becoming a modifier
G2211 is the add-on payment for office and outpatient visits that are part of a complex or ongoing care relationship. CMS wants to replace the separate code with a modifier attached to the evaluation and management visit. The final two-digit modifiers have not been named yet, so the proposed rule calls them MOD1 and MOD2 for now.
Two payment levels, and one is built for accountable care
MOD1 would increase payment for the visit by 16%. Any eligible practitioner could use it when the visit meets the requirements.
MOD2 is the one ACOs should watch. It would increase payment by 32% and would only be available to practitioners in a Medicare Shared Savings Program ACO or Participant Providers in the LEAD Model. CMS is acknowledging that ongoing care takes work beyond the visit. Practices are coordinating care. They are reporting quality. They are also responsible for total cost of care.
You could use the ACO modifier more broadly than you might expect
Claims billed with MOD2 would be included in the beneficiary assignment calculation. That means the modifier may help eligible primary care visits count toward attribution when the other assignment requirements are met.
But the same claims would also count in the ACO’s historical benchmark and performance-year spending. Using MOD2 more broadly could increase visit revenue now. It could also affect who is assigned to the ACO and the final shared savings calculation. Before making it part of your billing strategy, run the numbers.
The larger signal: CMS is moving payment closer to the work
Today, practices often wait until well after the care is delivered to see the financial benefit of shared savings. MOD2 would pay eligible practices on the claim, closer to when the work happens. It would not replace shared savings. It would, however, pay practices sooner for at least some of the work required to manage care.
This is bigger than one modifier. CMS is creating more ways for providers to participate in accountable care through models such as LEAD and the Ambulatory Specialty Model. The message is clear: CMS wants more providers in arrangements that connect payment to outcomes and cost. ACOs should think about what this means for revenue now and for their longer-term value-based care plans.
What to do before the rule is final
Start with your own claims. Look at where MOD1 and MOD2 could apply, then estimate what each would mean for visit revenue and beneficiary assignment. You also need to understand what the additional spending could do to your benchmark and year-end results.
If you are still deciding whether to join an ACO, add this proposal to the discussion. The higher visit payment matters, but so do the responsibilities that come with accountable care. Be honest about whether your organization is ready to manage quality and total cost over time.
Need help running the numbers?
Pinnacle Healthcare Consulting can help you understand what the proposed modifiers could mean for your organization. We can model the financial impact and look at how the change fits into your value-based care strategy. Contact us or send your question through AskPHC.com.
Source: CMS, Calendar Year 2027 Medicare Physician Fee Schedule Proposed Rule, issued July 14, 2026. The policy described above is proposed and may change before finalization.
