Provider Update: A New Payment Opportunity for ACO Participation (Proposed)

What CMS proposed

On July 14, 2026, CMS released its Calendar Year 2027 Physician Fee Schedule proposed rule. Tucked inside is a change to a code many primary care clinicians already know: G2211, the add-on you bill alongside an office/outpatient E/M visit to recognize the extra work of being the ongoing focal point for a patient's care.

Under the proposal, G2211 would be replaced by two new billing modifiers:

MOD1 — for clinicians not participating in a Medicare ACO MOD2 — for clinicians participating in the LEAD Model or the Medicare Shared Savings Program (MSSP) The headline: MOD2 would be paid at twice the rate of MOD1.

Why the difference? CMS is explicit about the reasoning. The higher MOD2 rate is meant to recognize the additional work of delivering accountable, coordinated care inside an ACO — the things you and your team already do every day:

Care coordination and transitions Population health management Patient outreach and engagement Quality measurement and reporting Performance improvement Use of advanced health IT and data analytics In other words, CMS is proposing to pay you directly, per visit, for the infrastructure and effort that accountable care requires.

What it means for you If you bill under a participant TIN in a LEAD ACO (or an MSSP ACO), the proposal would make you eligible to bill MOD2 — twice the payment a non-ACO clinician receives for the same longitudinal-care add-on.

A few things make this notable:

It's per-visit, fee-for-service revenue. This isn't a year-end shared-savings distribution — it's paid as you deliver care. It's separate from shared savings. MOD2 sits on top of any shared-savings upside your ACO generates. It scales with your panel. Because the add-on applies across your eligible primary-care visits, a 2× differential adds up over a full year. Put simply: it's another concrete way that being in an ACO pays — not eventually, but visit by visit.

Important: this is a proposal, not final We want to be straight with you about where this stands:

The rule is open for a 60-day public comment period. CMS will review feedback and issue a final rule before anything takes effect. Payment rates and exact billing rules are not yet finalized and could change. You don't need to do anything differently today. Keep billing G2211 as you do now. What to watch for Once CMS finalizes the rule, we'll publish clear, updated billing guidance and work directly with your billing and coding teams so you can capture MOD2 correctly and compliantly. We'll break down the final payment amounts, documentation expectations, and any workflow changes in plain language.

The bigger picture This proposal is part of a broader trend: CMS increasingly using the fee schedule to reward accountable-care participation directly, alongside the shared-savings opportunity that has always been at the heart of models like LEAD. For clinicians weighing whether ACO participation is worth it, the math keeps tilting in one direction.

We'll keep you posted as this moves from proposal to final rule.

Have questions about ACO participation or what this could mean for your practice? https://leadaco.com/contact

This post is for informational purposes only and reflects a proposed CMS policy that is subject to change. It is not billing, legal, or compliance advice. Final guidance will follow CMS's final rule. Source: CMS CY2027 Physician Fee Schedule proposed rule (file code CMS-1848-P), July 14, 2026.