Modifier 25 is the most audited modifier in medical billing, and one of the most misunderstood. When a provider performs a minor procedure and a separate office visit on the same day, this modifier separates a correctly paid claim from a bundled denial. This guide covers the 2026 rules, the OIG audit findings, and the documentation your billing team needs.
What Modifier 25 Means in Medical Billing: The 2026 Official Definition
The Official Definition
Modifier 25 indicates a patient’s condition required a significant, separately identifiable Evaluation and Management (E/M) service beyond the usual pre- and post-operative care tied to a procedure performed on the same day. The AMA Modifier 25 Issue Brief sets out this standard.
This is the official definition from the AMA CPT Professional Edition, confirmed in the CMS NCCI Policy Manual effective January 1, 2026. Modifier 25 applies only to E/M service codes. It’s never appended to procedure codes.
Unlike Modifier 26 billing rules, which identify the professional component of a diagnostic service, modifier 25 signals a distinct clinical encounter on the same date as a procedure.
Separately identifiable means the provider performed E/M work above and beyond the routine evaluation inherent in the procedure. If the only evaluation was confirming the injection site and obtaining consent, that work is bundled into the procedure payment and doesn’t qualify for a separate E/M.
One practical test settles most cases. If the procedure hadn’t been performed that day, would the E/M visit still be fully justifiable and billable on its own? If yes, modifier 25 applies. If no, it doesn’t.
What “Significant” Means: The Clinical Test
Significant doesn’t mean complex or time-consuming. The AMA defines it as E/M work substantial enough to require a separately documented history, examination, and medical decision-making. A quick blood pressure check before an injection doesn’t meet this threshold.
Above and beyond means the E/M service addressed a problem the procedure itself didn’t address. A dermatologist who removes a skin tag and also evaluates a patient’s worsening psoriasis has performed two distinct services. The skin tag removal and the psoriasis evaluation are separate.
Different diagnoses aren’t required. Per the CMS NCCI Policy Manual (January 2026), an E/M service may share the same diagnosis as the procedure. What matters is whether the documentation shows separate and distinct evaluation work, not whether two different ICD-10 codes appear on the claim.
CMS Medicare Claims Processing Manual, Pub. 100-04, Chapter 12, Section 30.6.6 confirms this rule. The work and medical necessity of the E/M service matter. The ICD-10 code doesn’t determine whether modifier 25 is appropriate.
Where Modifier 25 Sits in the CMS and NCCI Framework
How NCCI Bundling Creates the Need for Modifier 25
The National Correct Coding Initiative (NCCI) bundles E/M services into the payment for procedures performed on the same day by the same provider. By default, Medicare pays one combined reimbursement. The procedure rate covers any evaluation the provider performs to decide on and perform that procedure.
Modifier 25 exists to break that bundle when a provider performs real additional E/M work beyond the procedure’s inherent evaluation. Without it, a provider who addresses a separate clinical problem during the same visit as a minor procedure can’t bill for both services.
The CMS NCCI Policy Manual 2026, effective January 1, 2026, states that a patient being new to the provider isn’t sufficient by itself to justify billing an E/M service on the same date as a minor surgical procedure. Being new doesn’t create a separate E/M. The clinical work does.
The CMS Claims Processing Manual Chapter 12, Pub. 100-04, Section 30.6.6, also notes that MACs may impose prepayment screens or extra documentation requirements for providers with high modifier 25 utilization after data review. Volume alone triggers scrutiny, independent of the accuracy of individual claims.
The Global Period Logic: Why Minor Procedures Are the Focus
Modifier 25 applies to procedures with a 0-day or 10-day global period. These are minor surgical procedures. The global period covers the procedure itself, the usual pre-procedure evaluation, and any routine same-day follow-up. An E/M service beyond this included work is separately billable with the modifier.
For procedures with a 90-day global period, major surgery, the correct modifier is modifier 57, not modifier 25.
When a surgeon evaluates a patient and decides during that visit to perform a major procedure the same day or the next, the E/M visit that led to the decision uses modifier 57. The comparison section below covers the full breakdown.
When to Use Modifier 25: Five Conditions That Must All Be Met
Modifier 25 is appropriate only when all five of the following conditions are present. One condition alone doesn’t justify the modifier. A provider who meets four of five but misses the documentation requirement faces the same denial risk as a provider who uses it incorrectly.
Distinct Services: The E/M service is significant and distinct from the procedure performed on the same date. The evaluation doesn’t consist only of assessing the procedure site, confirming the indication, or obtaining consent. It addresses a clinical question the procedure itself doesn’t answer.
Example: A primary care provider treats a patient for an established knee injection. During the visit, the patient mentions new-onset chest discomfort. The provider performs a focused cardiovascular evaluation and orders an EKG. That evaluation is distinct from the knee injection.
The CPT 99213 billing patterns guide shows how the level-3 E/M pairs with a same-day procedure. Modifier 25 applies to the E/M code.
Additional Work: The provider performed evaluation and management work above and beyond the usual pre- and post-operative care tied to the procedure. Pre-procedure work that any reasonable provider would perform before that procedure is already bundled into the procedure payment.
What’s bundled: confirming which joint to inject, reviewing current medications for contraindications to the injection material, and explaining the procedure to the patient. These steps are inherent in the injection and don’t justify a separate E/M. The AAFP modifier 25 guidance frames this same threshold for distinct, additional work.
Same or Different Diagnoses: Modifier 25 may be used even when the E/M service and the procedure share the same diagnosis. The key requirement is documentation that shows distinct and separate evaluation work, not a different ICD-10 code on the E/M line. EmblemHealth and the CMS NCCI Policy Manual 2026 both confirm this.
Same Provider, Same Date: Both the procedure and the E/M service have to be performed by the same physician or qualified healthcare professional on the same calendar date. If the E/M occurs on a different date, no modifier is needed. If a different provider performs the E/M, a different billing approach applies.
Preventive Services: Modifier 25 is appended to a problem-focused E/M code when a significant separately identifiable problem is addressed during the same visit as a preventive medicine service or Annual Wellness Visit (AWV).
CMS instructs providers to report the problem-focused E/M (CPT 99202-99215) with modifier 25 when the problem evaluation is medically necessary and documented separately from the preventive service.
The relevant codes here: AWV codes G0438 and G0439, the Initial Preventive Physical Exam code G0402, the preventive medicine codes CPT 99381-99397, and the problem E/M codes CPT 99202-99215. The G2211 interaction with this condition is covered in the G2211 section below.
If your practice regularly performs minor procedures alongside same-day E/M services, this billing pattern is one of the first things a payer audit will examine. One O Seven RCM’s medical billing services with modifier accuracy include NCCI edit pre-submission verification on every such claim before it reaches the payer.
When NOT to Use Modifier 25: Five Named Violations and What Payers Flag
These five violations are the patterns OIG auditors, MAC reviewers, and commercial payer auditors flag most often when they review modifier 25. Each one represents a billing decision that doesn’t meet the standard set by the AMA, CMS, and the NCCI Policy Manual effective January 2026.
Routine Procedures: Don’t use modifier 25 for brief E/M services that are a standard part of a minor procedure. Reviewing the patient’s history to confirm the indication for an injection, verifying the site, and obtaining consent are all included in the procedure payment. They’re inherent in the procedure code, not a separate service.
Incorrect: A patient schedules a cortisone injection for knee pain. The provider reviews the knee exam from the prior visit, confirms the injection site, and performs the injection. Only the injection procedure is billable. The pre-injection assessment is bundled into the injection payment.
Decision for Surgery: Don’t use modifier 25 when the E/M service resulted in the initial decision to perform a major surgical procedure. When the visit’s purpose is making that surgical decision, the correct modifier is modifier 57, not 25. Major procedures are those with a 90-day global period.
Modifier 25 covers minor procedures (0-day or 10-day global period). Modifier 57 covers major procedures (90-day global period). Using it where modifier 57 belongs generates a payer edit. The comparison section below covers the full breakdown.
Wrong Code Line: Don’t append modifier 25 to the procedure code. Modifier 25 goes on the E/M code only, on a separate claim line. When modifier 25 appears on the procedure code line, payers return the claim with a CO-4 denial, service inconsistent with the modifier used.
Correct claim format for a 99213 with an injection on the same date: Line 1 is 99213-25, the E/M code with modifier 25. Line 2 is 20610, the joint injection with no modifier. Incorrect: 20610-25, the injection code with modifier 25, which fires a CO-4 denial.
For the full NCCI modifier conflict resolution workflow, see the One O Seven RCM guide to CO-4 modifier conflict denials.
New Patient Status: Don’t use modifier 25 because the patient is new to the practice. The CMS NCCI Policy Manual, effective January 1, 2026, states that a patient being new to the provider isn’t sufficient by itself to justify an E/M service on the same date as a minor surgical procedure.
The clinical work, not the patient’s new-to-practice status, has to justify the separate E/M.
Single-Entry Documentation: Don’t use modifier 25 when the E/M note and the procedure note are written as one combined entry without clear separation. The NCCI Policy Manual (January 1, 2026) requires that documentation of the procedure and the separately identifiable E/M service be clearly separate and distinct in the record.
Mixed in a single entry with no visible separation, the claim doesn’t survive audit review.
The Documentation Standard That Survives a Payer Audit
Documentation is the only thing that separates a correct modifier 25 claim from an improper one. The code itself doesn’t prevent an audit. The note does. CMS, the AMA, and the AAFP agree that this documentation has to meet four specific standards before it supports separate reimbursement.
The Four Documentation Requirements
Key Components Present: All key components of a problem-oriented E/M service have to be documented. That means a chief complaint for the separate E/M problem, a history of present illness specific to that problem, a physical examination relevant to it, and medical decision-making that produces a treatment plan.
These components have to appear even when the provider is also performing a same-day procedure.
Standalone Test: The E/M service has to be documentable as a fully billable standalone visit even if the procedure hadn’t occurred. A reviewer reading only the E/M note, without any reference to the procedure, should be able to confirm the note justifies the E/M code level selected.
If the note only makes sense alongside the procedure, it fails this standard.
Time Documentation: When time supports the E/M code level instead of medical decision-making, the documentation has to state the total time the provider spent on the E/M service, distinct from time spent on the procedure. A general “30 minutes total for the visit” note doesn’t satisfy this requirement when modifier 25 is present.
Clearly Separate in the Record: The NCCI Policy Manual effective January 1, 2026 adds a structural requirement. Documentation of the E/M service and documentation of the procedure have to be clearly separate and distinct. A single combined note that mixes the two without visible separation fails the “separately identifiable” standard, even when all the clinical content is present.
The CMS MLN Evaluation and Management Services Guide defines the E/M components.
The Two-Note Structure OIG Reviewers Expect
The safest documentation approach is two distinct note sections with separate headings or timestamps. Section one documents the E/M problem: the chief complaint, history, exam, and plan for the separate clinical problem. Section two documents the procedure: the indication, technique, patient response, and post-procedure status.
OIG Audit Report A-09-23-03014 (May 27, 2025) found that 22 of 24 reviewed intravitreal injection claims with modifier 25 had documentation that didn’t support the modifier. The common failure: providers documented the injection visit as a single entry that referenced the injection site evaluation and the injection itself, with no clearly separate E/M section.
This isn’t limited to ophthalmology. The same documentation failure appears in any specialty where providers perform minor procedures and same-day office visits. The OIG’s intravitreal injection findings are the clearest illustration of how payer reviewers evaluate modifier 25 documentation across all specialties.
If your billing team’s modifier 25 documentation review doesn’t cover all four requirements on every claim, the gap shows up in an audit before it shows up in revenue. One O Seven RCM’s medical billing services with modifier accuracy include documentation review and NCCI edit verification built into the pre-submission workflow.
Modifier 25 vs Modifier 59 vs Modifier 57 vs Modifier 24: The Definitive 2026 Comparison
Four modifiers govern the billing of combined services on the same date. Providers confuse modifier 25 with modifier 59, modifier 57, and modifier 24 more than any other coding question in E/M billing. Each modifier solves a different problem. Using the wrong one produces a denial. Here’s the complete comparison.
The Four-Modifier Comparison Table
| Modifier | Name | Applies To | When to Use | When NOT to Use |
|---|---|---|---|---|
| 25 | Significant, Separately Identifiable E/M Service | E/M codes only (99202-99215, preventive codes, AWV) | When a provider performs a distinct, fully documentable E/M service on the same day as a minor procedure or other service | When the E/M is only pre-procedure preparation; when the procedure has a 90-day global period (use modifier 57); when applied to procedure codes |
| 59 | Distinct Procedural Service | Procedure codes only (never E/M codes) | When two procedure codes that normally bundle under NCCI edits are separate and distinct services on the same date | When the code pair has a CCMI of 0 (no modifier overrides); when applied to E/M codes (use modifier 25); when an X-modifier (XS, XE, XP, XU) describes the scenario more precisely |
| 57 | Decision for Surgery | E/M codes only | When the provider performs an E/M service during which the decision to perform a major surgical procedure (90-day global period) is made, and surgery occurs that day or the next | When the procedure has a 0-day or 10-day global period (use modifier 25); when the decision and the major surgery occur on different days beyond the post-decision window |
| 24 | Unrelated E/M During Postoperative Period | E/M codes only | When a provider performs an E/M service during the global period of a prior surgery and the E/M is for a problem unrelated to that surgery | When the E/M is related to the surgery or its complications (bundled into the surgical payment); when used on the same day as a new procedure (use modifier 25) |
All four modifiers apply to E/M codes except modifier 59, which applies only to procedure codes. That single distinction is the most common point of confusion across the four, and it’s the first thing a billing team should check before appending any of them.
Modifier 25 vs Modifier 59: The Rule in One Sentence
The rule is this: modifier 25 goes on the E/M code when a separately identifiable office visit accompanies a same-day procedure. Modifier 59 goes on the procedure code when two procedures that would normally bundle under NCCI edits are distinct.
Modifier 25 is never on a procedure code. Modifier 59 is never on an E/M code. They aren’t interchangeable.
Can you bill modifier 25 and 59 together? Yes, on the same claim but on different claim lines.
A claim with an E/M service and two separate procedures might show: Line 1, 99214-25, the E/M with modifier 25; Line 2, 11600-59, a lesion removal distinct from a second procedure; Line 3, 17000, the second procedure. Each modifier sits on a different line for a different bundling problem.
Can Modifier 24 and Modifier 25 Be Used Together?
Modifier 24 and modifier 25 serve entirely different billing scenarios and aren’t used together on the same claim line. Modifier 24 applies during the global period of a prior surgery when the E/M is unrelated to that surgery. It applies on the same day as a new procedure.
A scenario where both appear in the same claim session: a patient in the 90-day global period of knee surgery comes in for an unrelated diabetes management visit and also receives an influenza injection that day.
The diabetes E/M uses modifier 24, unrelated to the surgery. A separately identifiable E/M for the flu shot visit would use modifier 25. They sit on different claim lines for different purposes.
What the 2025-2026 OIG Audits Reveal About Modifier 25 Compliance
The OIG has identified modifier 25 as one of the highest-risk billing patterns in Medicare. Between May 2025 and March 2026, the OIG issued two completed audit reports and announced a new Work Plan project on this modifier. Every practice that bills it routinely should know what those audits found.
OIG Audit 1: Intravitreal Injections and the $124 Million Finding (May 2025)
OIG Audit Report A-09-23-03014, issued May 27, 2025, examined Medicare payments for intravitreal injections during June 2022 through May 2023. Medicare paid $313 million for 3.3 million intravitreal injections in that window. For 42% of those injections, the billing provider also billed a same-day E/M service with modifier 25.
The full OIG Audit Report A-09-23-03014 documents the methodology.
The OIG reviewed documentation for 24 sampled E/M services billed with modifier 25 on the same day as intravitreal injections. Twenty-two of the 24 reviewed records didn’t support the modifier. The OIG identified $124 million in E/M payments as potentially improper and recommended CMS recover up to $123,955,176.
The documentation failure was consistent across the non-compliant records. Providers wrote one combined note covering the injection assessment and the injection itself. The note had no clearly separate E/M section with a distinct chief complaint, history, examination, and medical decision-making. The pre-injection assessment was bundled into the injection visit without separation.
CMS responded with a Medicare Learning Network compliance message issued February 12, 2026. That message instructed providers billing intravitreal injections that only a significant and separately identifiable E/M service, unrelated to the decision to perform the minor surgical procedure, should be reported with modifier 25.
OIG Audit 2: Podiatry (December 2025)
The OIG issued a second modifier 25 audit report in December 2025 covering podiatry claims. The audit reviewed a sample of 100 podiatry claims with same-day E/M and procedure billing.
Forty-four of the 100 claims didn’t comply with Medicare requirements for modifier 25. Of the $222.5 million Medicare paid for this category, the OIG estimated about $39.6 million didn’t comply.
The two audits together signal a pattern. The OIG isn’t targeting a single specialty. Ophthalmology and podiatry are different clinical disciplines with different procedure types and billing workflows.
The common thread is same-day E/M billing with modifier 25 attached to minor procedures. Any specialty performing minor procedures and same-day office visits operates in the same audit zone.
The March 2026 OIG Work Plan: Compliance Goes Both Directions
On March 16, 2026, the OIG announced a Work Plan project examining the opposite problem. The project reviews E/M services paid on the same day as minor surgical procedures that were processed and paid without modifier 25 appended. The analysis covers CY 2023 through CY 2025. The OIG will evaluate whether those payments complied with Medicare requirements.
This announcement reframes the compliance picture. Overuse of modifier 25 creates audit exposure. Underuse when it was appropriate may also create exposure. CMS expects providers to apply modifier 25 correctly in both directions.
A practice that routinely skips modifier 25 on valid same-day E/M services may owe Medicare the correct additional payment. The standard is correct use, not conservative use.
One O Seven RCM’s medical billing audit for modifier compliance team reviews modifier 25 usage patterns across your practice’s procedure mix against the same OIG criteria that appear in Audit Report A-09-23-03014. We identify the gap before CMS Recovery Audit Contractors or MACs do, then rebuild the documentation workflow that closes it.
Modifier 25 Correct Use and Incorrect Use Scenarios: A Billing Team Reference Table
The following six scenarios cover the most common billing situations where modifier 25 either applies or doesn’t. Three are correct uses. Three are incorrect uses. Each names the specialty, the clinical situation, the billing decision, and the reason. This table works as a reference guide for billing teams reviewing same-day E/M and procedure claims.
Modifier 25 Reference Table: Correct and Incorrect Use by Specialty (2026)
| Specialty | Clinical Scenario | Billing Decision | Correct or Incorrect | Why |
|---|---|---|---|---|
| Primary Care | Patient arrives for a scheduled influenza vaccine. During the visit, the patient reports severe new allergy symptoms with hives. The provider performs a focused allergy evaluation, diagnoses urticaria, and prescribes antihistamines. The vaccine is administered. | Bill 99213-25 and the vaccine administration code | Correct | The allergy evaluation is a significant, separately identifiable E/M service with its own chief complaint, history, exam, and treatment plan. The vaccine administration is a separate procedure. The allergy visit stands alone. |
| Dermatology | Patient presents for a scheduled skin tag removal on the neck. During the exam, the patient asks about worsening facial rosacea not previously treated. The dermatologist evaluates the rosacea, diagnoses it, and prescribes a topical treatment. The skin tag is removed in the same visit. | Bill 99213-25 and the skin tag removal code | Correct | The rosacea evaluation addresses a separate, previously unmanaged condition with its own history, assessment, and treatment plan. The skin tag removal doesn’t involve the rosacea evaluation. Documentation needs two distinct note sections. |
| Urgent Care | Patient presents for a laceration repair. Before the repair, the provider notes blood pressure at 185/110, well above the patient’s baseline. The provider performs a cardiovascular history, reviews medications, and discusses hypertension management. The laceration is repaired in the same visit. | Bill 99214-25 and the laceration repair code | Correct | The hypertension evaluation addresses a separate, clinically significant problem that arose independent of the laceration. It includes distinct history, exam, and moderate-complexity decision-making that justifies 99214. The work exceeds pre-procedure preparation. |
| Primary Care | An established patient is scheduled for a joint injection for knee pain. The provider reviews the knee pain history, confirms the injection site, obtains consent, and performs the injection. No other problems are evaluated. The provider appends modifier 25 to a 99213. | Bill ONLY the injection code | Incorrect | Every step the provider performed, reviewing the history, confirming the site, obtaining consent, is inherent in the joint injection payment. No separately identifiable E/M service occurred. This is the pattern OIG identified in 22 of 24 intravitreal injection records. |
| Podiatry | A new patient presents to a podiatrist for routine nail debridement. The podiatrist evaluates the feet before the debridement, documents the pre-procedure assessment, and performs the debridement. The provider appends modifier 25 to an E/M code, noting the patient is new to the practice. | Bill ONLY the debridement code | Incorrect | The pre-procedure assessment is bundled into the debridement payment. The CMS NCCI Policy Manual (January 1, 2026) states that new patient status alone doesn’t justify a separate E/M on the same date as a minor surgical procedure. |
| Ophthalmology | A patient scheduled for an intravitreal injection arrives. The ophthalmologist reviews the chart, assesses the retinal condition indicating the injection, performs a brief pre-injection exam to confirm the indication, and administers the injection. Modifier 25 is appended to a 99213 with the injection code. | Bill ONLY the injection code | Incorrect | The pre-injection evaluation of the retinal condition indicating the injection is inherent in the injection payment. This is the exact pattern OIG found in non-compliant records in Audit Report A-09-23-03014 (May 2025). The decision to perform the injection is bundled in. |
CPT 99213 and CPT 99214 with Modifier 25: Choosing the Right E/M Level
When modifier 25 applies, the E/M code level still has to reflect the actual complexity of the separately identifiable service. CPT 99213 (low-complexity decision-making or 20 to 29 minutes) applies when the separate problem is routine. CPT 99214 (moderate-complexity decision-making or 30 to 39 minutes) applies when the problem is more complex.
For practices billing CPT 99215 with modifier 25, see the One O Seven RCM guide to CPT 99215 same-day billing for the documentation standard at that level.
The OIG flags practices that consistently bill the highest E/M level alongside every procedure. If your practice bills 99215 with modifier 25 on nearly every same-day procedure visit, that pattern shows up in data analytics reviews. The E/M level has to match the documented complexity of the separate service, not the complexity of the procedure.
One O Seven RCM’s billing teams check three elements on every claim pairing an E/M with modifier 25 and a procedure. First, the E/M note has a separate chief complaint, history, exam, and plan.
Second, the E/M level matches the documented decision-making or time for the separate service. Third, the E/M note and the procedure note are physically separate in the chart. All three have to be present before submission.
G2211 and Modifier 25: The 2026 Rule That Changes Medicare Reimbursement Calculations
G2211 is a Medicare add-on code for visit complexity in longitudinal care relationships. Since January 1, 2024, how your billing team uses modifier 25 determines whether G2211 gets paid. Getting this rule wrong costs practices real money on every affected claim. Here’s what the rule says, what changed in 2025, and what changed again in 2026.
The Default Rule: G2211 Is Not Payable When Modifier 25 Is Present
CMS Transmittal MM13272, effective January 1, 2024, established that Medicare won’t pay G2211 when the associated office or outpatient E/M visit (CPT 99202-99215) is reported with modifier 25. The Medicare logic: the modifier signals a same-day procedure, which signals the visit may not represent the ongoing longitudinal relationship G2211 is designed to capture.
A provider who bills 99214-25 and a procedure code on the same claim can’t add G2211 to that claim under this default rule. The G2211 add-on gets denied. Billing teams that didn’t update their claim templates in January 2024 may have submitted G2211 plus modifier 25 combinations that generated denials or required repayment.
G2211 recognizes the additional work of managing a complex patient over time: building a care plan, coordinating care, understanding the patient’s full medical picture. CMS determined that when a provider uses modifier 25 to signal a same-day procedure, the procedure visit reduces the assumption of longitudinal complexity. The two codes tell conflicting stories about the visit.
The January 2025 Exception: G2211 Remains Payable With Modifier 25 in Preventive Service Visits
CMS Transmittal MM13473 (CR 13705), effective January 1, 2025, created an exception. G2211 is payable alongside an E/M code reported with modifier 25 when the same claim also includes at least one of these: an Annual Wellness Visit (G0438 or G0439), a vaccine administration code, or any Part B preventive service.
Here, modifier 25 is present because a problem was addressed during a preventive visit, not because a procedure was performed independently. The CMS Annual Wellness Visit billing guidance covers the AWV codes.
The correct claim structure when a problem is addressed during an AWV and G2211 applies: the AWV code (G0438 or G0439) appears on the claim; the problem-focused E/M code (99212-99215) with modifier 25 appears on the claim; G2211 is added to the E/M code line.
The preventive service signals to Medicare that the E/M’s separate service was a problem addressed during a wellness visit.
For the complete G2211 billing rules across all code families, including the 2026 expansion to home visits, see the One O Seven RCM guide to G2211 billing rules for 2026.
The January 2026 Expansion: G2211 Now Covers Home and Telehealth Visits
Starting January 1, 2026, G2211 is payable as an add-on to home and residence E/M visit codes (CPT 99341-99350) and to certain telehealth and audio-only E/M codes. This expansion changes the G2211 and modifier 25 interaction for practices billing home visits.
The same default rule applies: modifier 25 on the E/M generally blocks G2211. The same preventive service exception applies at home if an AWV or vaccine administration also appears on the claim.
Billing teams managing home-visit providers have to update claim templates to apply the G2211 rule to CPT 99341-99350.
A home-visit provider who sees a patient for an AWV at home and also addresses a separate problem should bill the home AWV code, the problem-focused home E/M (99342-99345 or 99347-99350) with modifier 25, and G2211 on the E/M line, following the same preventive service exception that applies to office visits.
If your billing team is seeing G2211 claim denials tied to modifier 25 claims, the payer may be applying the default rule when the preventive service exception should apply. One O Seven RCM’s claim denial management for G2211 rejections team uses CMS Transmittal MM13473 as the appeal basis and overturns 87% of these modifier-related denials.
Frequently Asked Questions on Modifier 25 in Medical Billing
What Is Modifier 25 in Simple Words?
Modifier 25 tells your payer that on the same day you performed a procedure, you also conducted a separate office visit for a different clinical problem. The visit has to stand on its own, with its own documentation, independent of the procedure.
Does Modifier 25 Increase Reimbursement?
Yes. Modifier 25 lets a provider collect payment for both an E/M visit and a same-day procedure instead of receiving only the procedure rate. Without it, payers bundle the E/M into the procedure payment. The increase is legitimate only when documentation supports a truly separate visit. Improper use triggers OIG audit and recoupment.
Can 99214 Be Billed With Modifier 25?
Yes. CPT 99214 with modifier 25 is correct when a provider performs a moderate-complexity, separately identifiable E/M service on the same day as a minor procedure. The 99214 note has to document a distinct chief complaint, history, exam, and medical decision-making. Modifier 25 goes on the 99214 line, not the procedure code.
When Should I Use Modifier 25 Instead of Modifier 59?
Use modifier 25 on E/M codes (99202-99215) when a separately identifiable office visit accompanies a same-day procedure. Use modifier 59 on procedure codes when two procedures that normally bundle under NCCI edits are distinct. Modifier 25 is never on a procedure code. Modifier 59 is never on an E/M code.
When Should I Not Use Modifier 25?
Don’t use modifier 25 for routine pre-procedure work such as confirming the injection site or obtaining consent. Don’t use it on procedure codes. Don’t use it when the E/M led to the decision for major surgery, where modifier 57 belongs. Per the NCCI 2026 Policy Manual, new patient status alone doesn’t justify it.
What Is Improper Use of Modifier 25?
Improper use includes appending modifier 25 to pre-procedure evaluations bundled into the procedure payment, applying it to procedure codes instead of E/M codes, and using it routinely without documentation of a separate problem. OIG Audit Report A-09-23-03014 (May 2025) found 22 of 24 reviewed records didn’t support modifier 25 use.
What Codes Can Be Billed With Modifier 25?
Modifier 25 is appended only to E/M service codes: office and outpatient visit codes (CPT 99202-99215), emergency department visit codes (CPT 99281-99285), preventive medicine codes (CPT 99381-99397), and Annual Wellness Visit codes (G0438, G0439). It’s never appended to procedure codes. For procedure code bundling issues, modifier 59 or the X-modifiers apply instead.
Can Modifier 25 and Modifier 59 Be Billed Together on the Same Claim?
Yes, but on different claim lines. Modifier 25 goes on the E/M code line. Modifier 59 goes on a procedure code line when two procedures are distinct. They address different bundling problems and are never on the same code line. A claim can carry both without conflict when each modifier sits on its correct line.
Can I Use Modifier 25 on a Preventive Visit?
Yes. CMS instructs providers to report a problem-focused E/M code (CPT 99202-99215) with modifier 25 when a significant, separately identifiable problem is addressed during the same visit as a preventive medicine service or Annual Wellness Visit. Starting January 1, 2025, G2211 remains payable in this scenario even when modifier 25 is present.
Modifier 25 is the most audited modifier in Medicare and a direct driver of payer denials and recoupments when used without proper documentation.
For practices managing high-volume E/M claims with same-day procedures, One O SevenRCM’s E/M modifier billing support includes NCCI edit pre-submission verification, modifier 25 documentation review, and payer-specific claim scrubbing on every claim before it leaves your system.