New 2027 Advance Care Planning Codes: What G0572 and G0573 Mean for Nurse-Led ACP

What are the new 2027 advance care planning codes for clinical staff?

As of November 2026, G0572 and G0573 are new Medicare HCPCS codes that pay for advance care planning furnished by clinical staff under the direct supervision of the billing practitioner. CMS finalized them on November 4, 2026, effective January 1, 2027. G0572 covers the first 20 minutes of staff time, G0573 covers each additional 20 minutes, and CPT 99497 and 99498 now cover practitioner time only.

• Effective date: Staff advance care planning time with dates of service on or after January 1, 2027, moves to the new G-codes.
• Combined time: Practitioner minutes can be added to staff minutes to reach the 20-minute threshold, but no minute can count toward two codes.
• Not an AWV add-on: Staff-led ACP is billed as a physician service tied to managing an illness, so the annual wellness visit cost-sharing waiver should not be assumed.

What CMS Finalized for ACP in 2027

On November 4, 2026, CMS released the CY 2027 Medicare Physician Fee Schedule final rule (CMS-1848-F, Federal Register document 2026-22743), scheduled for publication on November 9 and effective January 1, 2027. Most coverage has focused on the 2.31% cut to the non-QP conversion factor and the delayed remote monitoring staffing rule. A smaller provision changes advance care planning billing for every practice that uses nurses to lead the conversation.

CMS finalized G0572 (formerly GACP1) as proposed, covering the first 20 minutes of clinical staff time explaining advance directives with the patient, family, or surrogate, including completing standard forms when performed. G0573 (formerly GACP2) covers each additional 20 minutes of clinical staff time. CPT 99497 and 99498 are now reserved for time the billing practitioner personally spends, and both code families can be reported together when each meets its own time threshold.

Two final-rule details matter most in practice. First, if staff time alone falls short of 20 minutes, practitioner time can be counted with it to reach the G0572 threshold, as long as those minutes are not also reported under 99497. Second, CMS added both codes to the Medicare Telehealth Services List for 2027 and restated that direct supervision can be met through real-time audio and video.

CMS valued G0572 at 1.00 work RVU and G0573 at 0.70, the same work values as chronic care management codes 99490 and 99439. Final payment amounts sit in the addenda on the CMS-1848-F regulation page. CMS also reported that ACP use grew from about 650,000 services in 2016 to about 2.5 million in 2025, which it still considers short of the need.

Factor	Through December 31, 2026	Starting January 1, 2027
Practitioner ACP time	CPT 99497 and 99498	CPT 99497 and 99498, practitioner time only
Clinical staff ACP time	CPT 99497 and 99498, billed incident-to	HCPCS G0572 and G0573
Time structure for staff	30-minute blocks, 16-minute minimum	20-minute blocks; practitioner time can help meet the first
Work RVU for staff time	1.50 under 99497	1.00 for G0572, 0.70 for G0573
Telehealth	99497 and 99498 on the list	G0572 and G0573 added to the list

Which practices does the 2027 ACP coding change affect?

The change affects every practice that bills Medicare for advance care planning time spent by nurses or other clinical staff. Primary care, geriatrics, cardiology, oncology, nephrology, and pulmonology practices feel it most, because they manage serious chronic illness and already delegate much of the conversation to staff during follow-up care.

Three groups need to act. The first is practices that already bill 99497 incident-to when a nurse leads the discussion. Starting January 1, that staff time belongs on G0572 and G0573. These practices need new charge codes, new EHR templates, and a documentation habit that records whose minutes are whose.

The second group is practices where physicians handle ACP alone. For them, the new codes create a real reason to delegate. Staff time now has a dedicated payment path, so the physician can spend a few minutes confirming goals and signing orders instead of 30 minutes walking through forms.

The third group is practices that rarely bill ACP at all because nobody has time for the conversation. This group has the most to gain. ACP produces completed directives and the documentation that value-based contracts increasingly expect, yet it is usually the first thing cut from a crowded visit. CMS also added the new codes to the primary care services used for Shared Savings Program assignment, so ACO practices have one more reason to build the workflow.

One question we hear constantly from practice managers is whether this change only matters to large groups. It does not. A solo internist with a heavy Medicare panel has the same coding switch to make, and arguably more to gain, because every minute the physician gets back is a minute the practice cannot hire around.

How much practitioner time does nurse-led ACP free up?

In a typical model, moving the education and forms portion of advance care planning to a nurse cuts practitioner time per conversation from about 30 minutes to about 10. For a practice running 400 ACP conversations a year, that returns roughly 130 practitioner hours, or about 400 twenty-minute visit slots.

Here is the math behind that answer, as an illustrative planning model rather than an industry benchmark. Picture a four-physician primary care practice with 1,600 Medicare patients that sets a goal of holding an ACP conversation with one in four of them each year. That is 400 conversations.

If physicians run every conversation at about 30 minutes, the practice spends 200 physician hours a year on ACP. In a nurse-led model, the nurse handles the education, values discussion, surrogate identification, and form completion, reported with G0572 and G0573 when time supports it. The physician then spends about 10 minutes reviewing goals and confirming orders, often inside a visit already on the schedule. Physician time falls to roughly 67 hours, freeing about 133 hours. At 20 minutes per established visit, that is roughly 400 appointment slots. Multiply by your average established visit payment to see what the reclaimed time is worth before counting a dollar of ACP revenue.

In the workflow reviews we run during consultations, ACP is one of the first tasks physicians say they want to hand off and one of the last they actually delegate. The reason is rarely the conversation. It is the follow-up: mailing forms, chasing signatures, and getting completed directives back into the chart, which nobody owns.

What should practices do before January 1, 2027?

Practices should audit current ACP billing, update codes and templates, separate staff and practitioner time, confirm supervision and staff qualifications, tie each ACP service to a condition being managed, check payer policies, and build an outreach list. These eight steps keep staff-led ACP claims clean from the first week of the year.

1. Audit your current ACP billing. Pull 2026 claims for 99497 and 99498 and flag every encounter where a nurse or other staff member led the conversation.
2. Update your charge master and EHR templates. Load G0572 and G0573 and restrict 99497 and 99498 to practitioner-only time.
3. Separate time documentation. Record staff and practitioner minutes in distinct fields so no minute supports two codes.
4. Confirm your supervision setup. Decide how direct supervision is met at each location, in person or through real-time audio and video.
5. Verify staff qualifications. Confirm that everyone whose time you report meets incident-to rules and the licensure requirements of the state where the service is furnished.
6. Tie ACP to a managed condition. Document the condition discussed and the prior visit for it, since staff ACP is billed as a medically necessary physician service.
7. Check payer policies. Ask Medicare Advantage and commercial payers whether they will recognize the new G-codes in 2027.
8. Build your outreach list. Identify patients with serious or progressing chronic conditions, new serious diagnoses, and recent hospital discharges.

Our team has seen the same pattern across practices: once a nurse owns the outreach list and the follow-up, completion rates climb because someone is accountable for every open directive.

Common Misreadings of the New ACP Codes

The first misreading is that nurses can no longer provide advance care planning. The opposite is true. The final rule gives clinical staff ACP its own codes. What changes is the code family, not who may hold the conversation. CMS also repeated that clinicians must never try to influence a patient’s ACP decisions.

The second misreading is that nothing changes until CMS issues more guidance. The rule is final, and claims for staff ACP time on or after January 1, 2027, should use the new G-codes. CMS has said it will update its ACP MLN fact sheet, but practices that wait for it before updating templates risk a quarter of mismatched claims.

The third misreading is that direct supervision means the physician must stand in the room. In the 2027 final rule, CMS restated that direct supervision for these services can be met through real-time audio and video, though not audio-only. Document how supervision was met for each encounter.

The fourth misreading is that staff-led ACP rides along with the annual wellness visit. CMS was explicit: ACP as part of the AWV is a preventive benefit, and AWV services cannot be furnished incident-to. Staff ACP under G0572 and G0573 is a physician service that must be reasonable and necessary for an illness, so do not promise patients the AWV cost-sharing waiver.

The fifth misreading is that the 2029 direct-employee requirement in the same rule applies to ACP. It does not. That delayed requirement covers remote patient monitoring and remote therapeutic monitoring only. ACP staff time follows the existing incident-to rules.

Where a Virtual RN Fits in ACP

Practices often come to us after an ACP initiative stalls. The physicians believe in it, the forms exist, and patients are willing, but the work between conversations never gets done. That gap is where a dedicated virtual RN creates the most value.

A virtual registered nurse can call patients on your outreach list to introduce ACP before their next visit, send your state’s advance directive forms, answer general questions about how directives work, and schedule time with the care team. After the conversation, the nurse can chase signatures, upload completed directives into the EHR, update surrogate contact details, and flag patients whose health status changes so the conversation is revisited. Many patients prefer a real person on sensitive calls like these, a pattern covered in our article on why patients prefer human over AI healthcare calls.

Billable G0572 and G0573 time is a separate question. It must come from staff who meet incident-to rules and the licensure requirements of the state where the service is furnished, under your practitioner’s direct supervision. Confirm with your compliance team before reporting any remote staff member’s time. The support work drives completion either way, and it frees your in-office nurses and practitioners to spend supervised, billable time on the conversations themselves.

Virtual RNS places licensed registered nurses who work exclusively for one practice, hold HIPAA training certificates, and work inside your systems. ACP also pairs naturally with care plan work, which our guide to a virtual nurse for chronic care management explains. Before choosing any partner, review our checklist on what to consider when choosing virtual nursing companies.

Frequently Asked Questions

Next Steps

• Modeling care program revenue? See our virtual nurse ROI guide for CCM, RPM, and AWV billing.
• Hiring locally? Read why a virtual RN is often faster than competing for local nurses.
• Ready to start? See how Virtual RNS works, from consultation to trial to go-live.