Modifier -25 Coding and Reimbursement
Overview
Modifier -25 (Significant, Separately Identifiable E/M)
Coding & Documentation Overview
CMS Proposes a 50% Payment Cut for Same-Day E/M Visits Billed with Modifier -25 (CY 2027 PFS Proposed Rule)
Why this alert exists: In the CY 2027 Medicare Physician Fee Schedule Proposed Rule (CMS-1848-P, published in the Federal Register July 16, 2026), CMS proposes to apply a multiple procedure payment reduction to E/M visits reported with modifier -25 on the same day as a procedure. Today those E/M services are paid at 100%. [VERIFY: dated claim — CMS-1848-P, 91 FR 43842]
Modifier -25 is used when a provider performs a significant, separately identifiable evaluation and management (E/M) service on the same day as a procedure or other service. The key is documentation showing the E/M work went beyond the routine pre- and post-procedure work already included in the procedure’s global package. Clear separation between the E/M note and the procedure note helps prevent denials and audits. Modifier -25 is the most scrutinized modifier in CPT® — and the most talked-about topic in urology coding.
- Office/outpatient E/M with same-day minor procedure (e.g., cystoscopy)
- Hospital/observation E/M with same-day 0-day-global procedure (e.g., stent placement)
- Injection visits (e.g., LHRH) where an additional problem is evaluated and managed
- ED E/M with same-day procedure
- A separate reason for the E/M (chief complaint / problem addressed)
- HPI, exam, and MDM that support additional work
- Assessment & plan for the evaluated condition — a full, forward-looking plan, not just “procedure done”
- Clear separation between the E/M note and the procedure note
- Medical necessity for the extra work on that date
- Modifier -25 is appended to the E/M code, not the procedure code
- E/M code selection follows standard E/M rules (place of service + MDM/time)
- A separate diagnosis is not required, but may strengthen medical necessity
- Routine consent/prep for the procedure is not a billable E/M with -25
- For a same-day decision for major surgery (90-day global), use -57, not -25
- E/M documentation reads like routine pre-procedure work only
- No clear medical necessity for the additional E/M work
- EHR templates auto-attach -25 without patient-specific support
- E/M and procedure documentation are not clearly separated
- Payer prepayment-review programs requesting records before paying -25 claims
Top Questions (quick answers)
Where do I put modifier -25?
Append -25 to the E/M code only. Do not append -25 to the procedure code.
Is Medicare cutting payment for E/M visits billed with modifier -25?
Not yet — but the CY 2027 proposed rule would pay only the highest-valued same-day service at 100% and cut the rest, including the -25 E/M, by 50%. Comments are due September 14, 2026. See the alert at the top of this page for a summary and how to comment.
What does “significant and separately identifiable” mean?
It means the E/M work included additional history, exam, and medical decision making beyond routine pre- and post-procedure services.
Do I need a different diagnosis for the E/M?
No. Neither CPT® nor Medicare requires a separate diagnosis, but documenting distinct problems or additional evaluation can strengthen medical necessity.
What’s the easiest way to reduce denials?
Keep the E/M documentation separate from the procedure note and clearly show the extra evaluation and plan.
Can I bill -25 for routine consent and procedure prep?
No. Routine pre-procedure work (consent, preparation, and routine history/physical tied to the procedure) is generally included in the procedure package.
The E/M must reflect additional evaluation and management work — and NCCI frames it as work
unrelated to the decision to perform the minor procedure. Working the patient up to figure out
what is going on is separately billable; a quick check that the patient is ready for a planned procedure is not.
When do I use -25 vs. -57?
Use -25 with same-day procedures carrying a 0- or 10-day global
(cystoscopy, stent placement, ureteroscopy, injections). Use -57 when the E/M includes the
decision for surgery for a 90-day global procedure (e.g., PCNL, vasectomy)
performed the same day or the next day. The decision for major surgery is excluded from the 90-day global; for minor procedures,
the same-day decision is included unless the E/M was truly significant and separate.
What if the E/M and procedure are for the same diagnosis?
A separate diagnosis is not required, but payers scrutinize claims when the same diagnosis supports both services.
Documentation should clearly show the additional E/M work performed — a distinct assessment and a forward-looking plan.
Why do I need -25 with an injection code that has no global period?
NCCI bundles E/M codes into many XXX-global services — LHRH injections
(96402), therapeutic injections (96372) — so a same-day E/M
still requires -25 to be paid. Some commercial payers go further and require -25 with services like urinalysis, uroflow,
or post-void residual. Payer rules vary down to the plan level; track them payer by payer. [VERIFY: payer-specific policies]
What are common procedures often seen with -25 in urology?
Examples include cystoscopy, cystoscopy with bladder Botox injection, prostate biopsy, LHRH and other therapeutic injections,
stent placement in the hospital, and urodynamic testing.
Remember: -25 goes on the E/M code, not the procedure code.
Payers are denying our -25 claims even with good documentation. Should we stop billing it?
No. If the documentation supports a significant, separately identifiable E/M, bill it — and appeal denials.
Payers count on attrition; practices that appeal consistently and support each appeal with documentation win in the aggregate,
and payers eventually back off accounts that always fight back. Prompt-pay laws in most states also put a clock (and interest)
on payers sitting on clean claims. [VERIFY: state prompt-pay specifics]