As of January 2025, CMS has expanded the use of HCPCS code G2211, marking an important change for providers, coders, and auditors working with E/M services. 

What Changed 

Previously, G2211 could not be reported on the same day as an E/M billed with modifier 25 for any reason. 

The 2025 CMS E/M guideline update removes that restriction if the modifier 25 application is due to an E/M that is billed with an Annual Wellness Visit (AWV), vaccine administration, or other Medicare Part B preventive services. 

Why This Matters 

This expansion acknowledges the longitudinal complexity of patient care—even when preventive services are delivered. Coders and auditors should keep in mind: 

  • More opportunities to bill G2211 = potential for increased utilization. 
  • Documentation is critical. The record must support that longitudinal care or complex decision-making occurred in addition to the preventive service. 
  • Audit implications. With wider use of G2211, compliance reviews will likely focus on whether documentation meets the intent of the code. 

Final Takeaway 

The 2025 change opens new billing opportunities while also raising compliance considerations. Organizations should prepare by educating providers, monitoring claims, and reinforcing documentation standards to ensure appropriate use of G2211. 

Learn more in the CMS MLN Matters Article on G2211 and the HCPCS G2211 Fact Sheet. 

Meet the Presenter: Leah Culley, CPC, CIC

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