Primary Care Billing Services: E/M Leveling, G2211, and the Revenue Opportunities Most Family Practices Miss
By Medtransic | February 15, 2026 | 16 min read | Updated: February 15, 2026
Quick Summary: Primary care billing looks simple on the surface — office visits, preventive exams, and vaccinations. But E/M leveling errors, missed G2211 add-on revenue, unbilled chronic care management, and the preventive vs. problem-oriented split create a gap between what practices earn and what they should be collecting.
At Medtransic, primary care billing is the specialty where we most frequently find revenue that practices didn't know they were leaving on the table. Unlike surgical specialties where the revenue gap comes from coding errors on high-value procedures, primary care revenue leaks come from systematic underbilling — E/M visits leveled too low, the G2211 add-on code not being billed at all, chronic care management services never initiated, and preventive visits that should have generated a separate problem-oriented E/M.
The numbers are striking. A primary care practice billing G2211 on qualifying visits can generate an additional $16 to $33 per Medicare visit — which across a typical panel can add $30,000+ per provider per year. Chronic care management (CCM) can add $60 to $140+ per eligible patient per month. Annual Wellness Visits with advance care planning and G2211 stacking can generate $200+ per encounter instead of $117. These aren't billing tricks — they're legitimate services that primary care practices already provide but don't capture because their billing company doesn't know these codes exist.
This guide covers the coding rules, revenue opportunities, and payer-specific traps that define primary care billing — and what your billing company should be doing to ensure you're collecting every dollar your practice earns.
Why Primary Care Billing Is More Complex Than It Looks
Primary care appears to be the simplest specialty to bill — office visits, wellness exams, vaccinations. But that simplicity is deceptive. A single primary care encounter can involve an E/M visit that must be leveled correctly based on medical decision-making complexity or time, a preventive service that requires a separate code and may or may not be billable on the same day as a problem-oriented visit, vaccinations that require both an administration code and a product code, and counseling services that are separately billable but rarely captured.
The real complexity in primary care billing isn't procedural — it's recognizing billable services that providers perform routinely but don't capture. Family physicians manage chronic conditions across visits (billable as CCM), coordinate care after hospitalizations (billable as TCM), conduct annual wellness visits with advance care planning including cardiovascular screening referrals (billable as separate add-on codes), and serve as the longitudinal focal point for patient care (billable as G2211). Most general billing companies submit the E/M code and move on, leaving thousands of dollars per month uncollected.
That's why Medtransic takes a revenue optimization approach to primary care billing — not just submitting claims accurately, but identifying every billable service the practice provides and ensuring it's captured.
E/M Coding: The Leveling Decisions That Drive Revenue
Evaluation and management codes are the backbone of primary care billing, accounting for the majority of revenue in most family medicine and internal medicine practices. E/M leveling is based on either medical decision-making (MDM) complexity or total time — and the choice between these two methods can significantly impact reimbursement. For a broader reference, see our CPT codes cheat sheet.
New Patient Office Visits
| CPT Code | MDM Level | Typical Time | Key Billing Notes |
|---|---|---|---|
| 99202 | Straightforward | 15-29 min | Self-limited problems, minimal data review. Lowest-level new patient visit. |
| 99203 | Low | 30-44 min | Low-complexity problems requiring prescription management or minor diagnostic workup. |
| 99204 | Moderate | 45-59 min | Multiple chronic conditions, moderate data review, prescription drug management. Most common new patient code in primary care. |
| 99205 | High | 60-74 min | Severe conditions, extensive data review, drug therapy requiring intensive monitoring. Document the complexity that justifies this level. |
Established Patient Office Visits
| CPT Code | MDM Level | Typical Time | Key Billing Notes |
|---|---|---|---|
| 99211 | May not require physician | — | Nurse visit for established problem (e.g., BP check, injection). No physician MDM required. |
| 99212 | Straightforward | 10-19 min | Self-limited problem, minimal data. Underbilled when practices default to 99213 for simple visits. |
| 99213 | Low | 20-29 min | Most commonly billed code in primary care. Low-complexity problems, limited data review. |
| 99214 | Moderate | 30-39 min | Multiple chronic conditions managed, moderate data review, prescription management. Frequently underbilled by practices that default to 99213. |
| 99215 | High | 40-54 min | Highest-level established visit. Complex decision-making, multiple conditions with risk of morbidity. Requires strong documentation. |
Time-Based vs. MDM-Based Leveling
Providers can select their E/M level based on either MDM complexity or total time spent on the encounter (including face-to-face and non-face-to-face time on the date of the encounter). When a provider spends significant time reviewing records, coordinating care, or counseling the patient, time-based coding often supports a higher E/M level than MDM alone. Medtransic advises providers on when time-based coding produces better reimbursement and ensures documentation captures the total time spent.
G2211: The Add-On Code Most Practices Aren't Billing
HCPCS add-on code G2211 is the single biggest missed revenue opportunity in primary care billing today. It reimburses approximately $16 to $33 per qualifying visit and can be billed on virtually every Medicare office visit where the provider serves as the patient's ongoing, longitudinal care manager.
| G2211 Detail | Information |
|---|---|
| What it pays | Approximately $16-$33 per visit (varies by geographic locality and APM participation) |
| Who can bill it | Any physician or NPP who reports E/M services and serves as the patient's longitudinal focal point |
| What it pairs with | E/M codes 99202-99205, 99211-99215, and as of 2025, Annual Wellness Visits (G0438, G0439) |
| Frequency limits | None — can be billed on every qualifying visit |
| Modifier -25 rule | As of January 2025, G2211 is payable even when the E/M code carries modifier -25, if the additional service is a covered Part B preventive service |
| Who pays | Medicare Part B. Medicare Advantage coverage varies by plan. Medicaid and commercial payers are not required to pay. |
G2211 captures the "visit complexity" that comes from managing a patient longitudinally — the cognitive work of knowing a patient's full history, coordinating their ongoing care, and serving as the focal point across multiple conditions. This is exactly what primary care physicians do on every visit, which is why the revenue potential is so significant.
G2211 is separate from care management codes like Chronic Care Management (CCM), Remote Patient Monitoring (RPM), and Transitional Care Management (TCM). G2211 captures complexity during the visit itself, while care management codes capture work between visits. A practice can and should be billing both — they are not duplicative.
Preventive vs. Problem-Oriented: The Same-Day Split
One of the most frequently missed revenue opportunities in primary care occurs when a patient comes in for a preventive visit (annual physical, well-child check) and the provider also addresses a new or existing problem during the same encounter. When this happens, both a preventive code AND a problem-oriented E/M code can be billed — but only with proper documentation and modifier usage.
| Preventive Visit Codes | Problem-Oriented E/M Codes |
|---|---|
| 99381-99397: Preventive medicine visits by age group (new and established patients) | 99202-99205: New patient office visits |
| G0438: Initial Annual Wellness Visit (Medicare) | 99211-99215: Established patient office visits |
| G0439: Subsequent Annual Wellness Visit (Medicare) | Billed with modifier -25 on the same day as a preventive visit |
| G0402: Welcome to Medicare / IPPE | Must address a separately identifiable clinical problem |
The critical rule: when billing a problem-oriented E/M on the same day as a preventive visit, append modifier -25 to the E/M code and ensure the documentation clearly shows two distinct services — the preventive evaluation AND the problem-oriented evaluation. The problem must be significant and separately identifiable, not just a brief mention of an existing condition during the wellness exam. A patient who comes in for their annual physical and during the visit reports new knee pain that requires evaluation, assessment, and a treatment plan — that's a separately billable E/M with -25.
Medtransic reviews every preventive visit encounter for potential same-day E/M opportunities. When the documentation supports a separately identifiable problem, we capture the additional E/M revenue. When it doesn't, we advise the provider on documentation practices that support legitimate same-day billing on future visits.
Chronic Care Management and Transitional Care: Revenue Between Visits
The most underutilized revenue source in primary care is care management billing — services performed between office visits that most practices provide but never bill. For a practice with a typical Medicare panel, CCM and TCM can generate tens of thousands of dollars per month in additional revenue.
Chronic Care Management (CCM)
| CPT Code | Description | Reimbursement (Approx.) | Key Requirements |
|---|---|---|---|
| 99490 | Non-complex CCM, first 20 min/month (clinical staff) | ~$60 | Patient must have 2+ chronic conditions expected to last 12+ months. Requires patient consent. Billed once per month. |
| 99439 | Each additional 20 min of non-complex CCM (add-on) | ~$46 | Add-on to 99490. Bill in units for each additional 20-minute increment. |
| 99491 | Non-complex CCM, first 30 min/month (physician/NPP) | ~$82 | Same eligibility as 99490 but requires direct physician/NPP involvement, not clinical staff. |
| 99437 | Each additional 30 min of physician-directed CCM (add-on) | ~$61 | Add-on to 99491. Bill for each additional 30-minute increment of physician time. |
| 99487 | Complex CCM, first 60 min/month (clinical staff) | ~$93 | Patients with complex conditions requiring substantial care coordination. Higher documentation threshold. |
| 99489 | Each additional 30 min of complex CCM (add-on) | ~$47 | Add-on to 99487 for additional complex care management time. |
Transitional Care Management (TCM)
| CPT Code | Description | Reimbursement (Approx.) | Key Requirements |
|---|---|---|---|
| 99495 | TCM, moderate complexity, face-to-face within 14 days of discharge | ~$235 | Patient discharged from hospital, SNF, or observation. Contact within 2 business days of discharge. Face-to-face visit within 14 days. |
| 99496 | TCM, high complexity, face-to-face within 7 days of discharge | ~$318 | Same discharge requirement. Contact within 2 business days. Face-to-face within 7 days. Higher MDM complexity. |
TCM is especially valuable because it reimburses at a significantly higher rate than a standard office visit ($235-$318 vs. $75-$140 for a 99213-99214) and includes a 30-day global period during which care management services are bundled in. The challenge is timing: the practice must contact the patient within 2 business days of discharge and schedule a face-to-face visit within 7 or 14 days. Medtransic tracks hospital discharge notifications and alerts practices to TCM-eligible patients so these high-value encounters aren't missed.
Annual Wellness Visits: The Medicare Revenue Most Practices Underutilize
Medicare Annual Wellness Visits (AWVs) are a significant revenue opportunity that most primary care practices underutilize. The AWV itself reimburses approximately $117-$173, but the real value is in stacking additional billable services during the same encounter.
| Code | Description | Reimbursement (Approx.) |
|---|---|---|
| G0402 | Welcome to Medicare / Initial Preventive Physical Exam (one-time) | ~$172 |
| G0438 | Initial Annual Wellness Visit (first AWV after G0402 or enrollment) | ~$173 |
| G0439 | Subsequent Annual Wellness Visit (annual) | ~$117 |
| G2211 | Visit complexity add-on (as of 2025, billable with AWV) | ~$16-33 |
| 99497 | Advance Care Planning, first 30 minutes | ~$86 |
| 99498 | Advance Care Planning, each additional 30 minutes | ~$76 |
| G0442 | Annual alcohol screening | ~$18 |
| G0443 | Alcohol counseling (15 min) | ~$27 |
| G0444 | Annual depression screening | ~$18 |
| G0477 | Obesity counseling (15 min) | ~$27 |
When advance care planning is performed on the same day as an AWV and billed with modifier -33, Medicare waives the patient's deductible and coinsurance — making it cost-free to the patient and more likely to be accepted. The documentation must include the total time spent discussing ACP, the topics covered, and any documents the patient signed. Medtransic advises providers on ACP documentation requirements and ensures the modifier -33 is applied correctly to eliminate patient cost-sharing.
The 7 Most Common Primary Care Denials (and How to Prevent Them)
Primary care denials are often lower in dollar value than surgical specialty denials — but they occur at high volume, creating a cumulative revenue loss that compounds month over month.
- E/M level downcoded by payer: Claim submitted at 99214 but payer downcodes to 99213 due to insufficient documentation of moderate MDM. Prevention: Medtransic audits E/M documentation before submission and flags claims where the documentation doesn't fully support the billed level.
- Modifier -25 denied on same-day preventive + E/M: Problem-oriented visit billed with a preventive visit without adequate documentation of a separately identifiable service. Prevention: We verify that the documentation shows two distinct clinical encounters — not just a brief mention of a problem during the wellness exam.
- Duplicate AWV billed within 12 months: Medicare allows only one AWV per 12-month period. If another provider already billed an AWV, the claim will be denied. Prevention: Medtransic runs eligibility checks for AWV coverage before the visit date.
- CCM billed without patient consent: Chronic care management requires documented patient consent before services can be billed. Missing consent = denial. Prevention: We track consent documentation for every CCM-enrolled patient and flag missing consents before the monthly billing cycle.
- Vaccination billed without administration code: Submitting the vaccine product code (90xxx) without the administration code (90471/90472 or 90473/90474) or vice versa. Both are required for proper reimbursement. Prevention: Our claim scrubbing verifies that every vaccine claim includes both product and administration codes.
- TCM timing requirements not met: Transitional care management requires contact within 2 business days of discharge and a face-to-face visit within 7 or 14 days. Missing either window means the TCM code cannot be billed. Prevention: Medtransic tracks discharge dates and alerts practices to TCM-eligible patients with timing deadlines.
- Preventive visit denied for frequency: Preventive exam codes have age-specific frequency limits that vary by payer. Billing a well-child visit or annual physical more frequently than the payer allows results in denial. Prevention: We verify age-appropriate preventive visit eligibility and payer-specific frequency rules before submission.
The 6 Revenue Opportunities Primary Care Practices Miss
Beyond preventing denials, the biggest value a specialized primary care billing company provides is identifying revenue the practice is earning but not capturing. These are the six most common missed opportunities we find when onboarding new primary care clients at Medtransic.
- G2211 not being billed: Most practices either don't know G2211 exists or believe it's too complex to implement. At ~$16-33 per qualifying Medicare visit with no frequency limits, this is the single largest missed revenue opportunity in primary care. Medtransic identifies qualifying visits and captures G2211 systematically.
- E/M visits systematically under-leveled: Many practices default to 99213 for established patients out of audit fear, even when documentation supports 99214. The ~$40-50 per-visit difference across thousands of annual visits represents the largest ongoing revenue leak. We audit E/M distribution patterns and identify systematic under-coding.
- CCM services not initiated: Most primary care practices have large numbers of patients with 2+ chronic conditions who qualify for monthly CCM billing ($60-$140+/month per patient), but have never enrolled them. Medtransic helps identify eligible patients and implement CCM workflows.
- TCM not captured after hospital discharges: Transitional care management reimburses $235-$318 per encounter — more than double a typical office visit — but requires specific timing. Without a system to track discharges, these high-value encounters are billed as standard visits. Medtransic implements discharge tracking protocols.
- AWV add-ons not stacked: Annual Wellness Visits are billed as standalone G0439 ($117) when they should include G2211 ($16-33), advance care planning ($86), depression screening ($18), alcohol screening ($18), and potentially a same-day E/M ($75-$140). Full stacking can more than triple AWV revenue per encounter.
- Counseling and behavioral health codes unused: Tobacco cessation counseling (99406/99407), behavioral health integration (99484), obesity counseling (G0447), and advance care planning (99497/99498) are all separately billable services that primary care providers routinely perform but rarely capture — services that overlap significantly with mental health billing workflows.
What to Demand From a Primary Care Billing Service
Primary care billing isn't just about submitting E/M claims correctly — it's about maximizing the revenue from every patient encounter and every between-visit service. Here's what to ask when evaluating a billing partner.
- E/M leveling audits: Ask whether they audit E/M code distribution patterns across your providers. If they can't show you a report of your 99213 vs. 99214 billing ratios compared to national benchmarks, they're not optimizing your revenue.
- G2211 billing process: Ask if they're billing G2211 for their primary care clients, how they identify qualifying visits, and what their monthly G2211 revenue capture looks like. If they've never heard of G2211, they're leaving significant money on the table.
- CCM program support: Ask whether they help practices identify CCM-eligible patients, track consent, and bill monthly CCM services. If they view CCM as outside their scope, they're missing the largest between-visit revenue opportunity in primary care.
- TCM discharge tracking: Ask how they identify TCM-eligible patients after hospital discharges and ensure the timing requirements (2-day contact, 7/14-day face-to-face) are met. If they don't have a discharge tracking workflow, you're losing $235-$318 per missed TCM encounter.
- AWV revenue stacking: Ask what the average total revenue per AWV encounter is across their clients. If it's just the G0439 rate ($117), they're not capturing add-on codes.
- Preventive + same-day E/M capture rate: Ask what percentage of their preventive visits also generate a same-day problem-oriented E/M. If they don't track this metric, they're not looking for the opportunity.
- Denial rate and revenue per provider: Ask for both denial rate and average revenue per provider per month. In primary care, low denial rates matter, but revenue per provider is the metric that reveals whether they're capturing all billable services.
- Coding update awareness: Ask about recent primary care billing changes — G2211 expansion to AWVs, CCM code updates, APCM program. If they can't discuss these without looking them up, they're not staying current.
At Medtransic, primary care billing is a core specialty where we focus not just on claim accuracy but on comprehensive revenue cycle management. We audit E/M leveling, capture G2211 on every qualifying visit, implement CCM and TCM programs, stack AWV add-on codes, and identify counseling and screening revenue that general billing companies consistently miss. The result isn't just cleaner claims — it's measurably higher revenue per provider.
- 97%+ Clean Claim Rate - Primary care claims accepted on first submission
- <4% Denial Rate - Across Medtransic primary care clients
- <28 days Average Days in AR - For primary care practices using Medtransic
- 15-25% Revenue Increase - Typical improvement within 90 days of onboarding
Frequently Asked Questions
What makes primary care billing different from other specialties?
Primary care billing appears straightforward but has unique complexity: E/M leveling decisions on every visit, the preventive vs. problem-oriented same-day split, add-on codes like G2211 that most practices don't bill, chronic care management revenue between visits, transitional care management with strict timing requirements, and annual wellness visit stacking with screening and counseling codes. The revenue gap in primary care comes from systematic underbilling of legitimate services, not from coding errors on individual claims.
What is G2211 and how much revenue can it generate?
G2211 is an HCPCS add-on code that reimburses approximately $16-$33 per qualifying Medicare visit for the "visit complexity" of serving as a patient's ongoing, longitudinal care provider. It can be billed with every qualifying E/M visit (99202-99215) and, as of 2025, with Annual Wellness Visits (G0438/G0439). There are no frequency limits. A primary care provider seeing 20 Medicare patients per day could generate $30,000-$80,000+ per year in additional revenue from G2211 alone.
Can I bill an office visit and a preventive visit on the same day?
Yes. When a patient comes in for a preventive visit (annual physical, AWV) and the provider also evaluates and manages a separately identifiable clinical problem, both a preventive code and a problem-oriented E/M code can be billed. Append modifier -25 to the E/M code and ensure the documentation clearly shows two distinct services — the preventive evaluation and the problem-oriented evaluation addressing a separate clinical issue.
What is Chronic Care Management (CCM) and how does it work?
CCM allows primary care practices to bill monthly for care coordination services provided to Medicare patients with two or more chronic conditions expected to last 12+ months. The primary code (99490) reimburses approximately $60 for the first 20 minutes of non-complex care management per month, with add-on codes for additional time. CCM requires documented patient consent and can be performed by clinical staff under physician supervision. A practice with 200 CCM-eligible patients billing 99490 monthly generates approximately $144,000/year in additional revenue.
How does Transitional Care Management (TCM) billing work?
TCM is billed when a practice manages a patient's care after discharge from a hospital, SNF, or observation stay. It requires contact within 2 business days of discharge and a face-to-face visit within 7 days (99496, ~$318) or 14 days (99495, ~$235). TCM reimburses at more than double a standard office visit and includes a 30-day global period. The challenge is identifying discharged patients and meeting the timing windows — without a tracking system, most TCM-eligible encounters are billed as standard visits.
What add-on codes can be billed with an Annual Wellness Visit?
AWVs can be stacked with several add-on codes: G2211 (visit complexity, ~$16-33), 99497/99498 (advance care planning, ~$86/$76), G0444 (depression screening, ~$18), G0442/G0443 (alcohol screening/counseling, ~$18/$27), G0477 (obesity counseling, ~$27), and a problem-oriented E/M with modifier -25 if a separate clinical issue is addressed. Full stacking can increase AWV encounter revenue from ~$117 to $300+ per visit.
How much do primary care billing services cost?
Primary care billing services typically cost 4% to 7% of monthly collections, depending on practice size, patient volume, and service scope. The ROI in primary care is driven less by reducing denials (which tend to be lower-dollar) and more by capturing revenue the practice is currently missing — G2211 add-on billing, CCM/TCM program implementation, AWV stacking, and E/M leveling optimization. Most practices see a 15-25% increase in total revenue within 90 days of switching to a specialized primary care billing company.
What is the difference between G2211 and Chronic Care Management?
G2211 is an add-on code that captures visit complexity during an office visit — it recognizes the cognitive work of managing a patient longitudinally during the face-to-face encounter. CCM codes (99490, 99491, etc.) capture care coordination work performed between visits — phone calls, medication reviews, care plan updates, and coordination with other providers. They are not duplicative and can both be billed for the same patient. G2211 captures in-visit complexity; CCM captures between-visit management.
Your Primary Care Practice Is Leaving Revenue on the Table
Medtransic provides specialized primary care billing services with E/M leveling optimization, G2211 capture, CCM/TCM program implementation, AWV revenue stacking, and revenue-per-provider tracking. We work with solo family physicians, multi-provider primary care groups, and internal medicine practices across the country.