Modifier -25 Coding and Reimbursement

Overview

Modifier -25 (Significant, Separately Identifiable E/M)
Coding & Documentation Overview

Alert — Proposed Rule · Comments Due September 14, 2026

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]

What CMS proposed
  • How it would work: When a separately identifiable E/M is furnished by the same physician (or practice) on the same day as a global-period procedure, the highest-valued service on the claim — procedure or E/M — would be paid at 100%, and every other service subject to the reduction, now including the E/M, would be paid at 50%. [VERIFY: CMS fact sheet]
  • Cysto example: Surveillance visit with a same-day cystoscopy — the cysto (higher valued) pays 100%; the E/M with -25 pays 50%.
  • Injection example: E/M with a same-day lower-valued service (e.g., an injection or catheter change) — the E/M pays 100% and the procedure takes the 50% cut.
  • Documentation rules do not change: The E/M must still be significant and separately identifiable. This is a payment proposal, not a relaxation of -25 requirements.
CMS — CY 2027 PFS Proposed Rule · July 2026
Also in the same rule
  • G2211 becomes a modifier: CMS proposes replacing the G2211 visit-complexity add-on with a modifier paying a percentage of the E/M (about 16%; higher for ACO participants) — but it still could not be reported when modifier -25 is required, so it does not offset this cut. [VERIFY: proposed policy detail]
  • Conversion factor: Proposed at $32.84 (non-QP, −1.68%) / $33.17 (qualifying APM participants, −1.19%). [VERIFY: proposed CFs]
  • A smaller cut was floated: CMS's discussion acknowledges the reduction percentage is open to comment, including a smaller reduction (e.g., 25%) instead of 50%. [VERIFY: rule text — sourced from PRS podcast review of the rule]
The impact — and what it means for urology

A large share of urology E/M is legitimately billed with modifier -25 — same-day cystoscopies, injection visits, in-office procedures. The 50% reduction is taken mostly out of physician work, yet the work of a separately identifiable E/M does not overlap the procedure's valuation — and procedure work RVUs already carry an adjustment for potential same-day E/M overlap, so this proposal double-counts. CMS did not list urology among the most-impacted specialties, but the practical revenue impact on urology practices is significant. Commercial payers in several states have already tried 50% reductions on -25 E/M; a finalized CMS policy would open that door wider. [VERIFY: PRS analysis]

PRS Recommendation

Comment. Individually and through your societies. This is a proposed rule — CMS has changed course on -25 reductions before when specialties pushed back, and the agency signaled openness to a smaller reduction. Argue the work-overlap point, the double-count point, and the patient-access point (same-day care saves patients a second trip). And regardless of the outcome: keep your -25 documentation bulletproof — the payment may change, but the documentation requirements will not go away.

How to submit a comment to CMS (due September 14, 2026)
  • Online (easiest): Go to regulations.gov/docket/CMS-2026-2377 (or search regulations.gov for “CMS-1848-P”), click “Comment”, paste or attach your comment, fill in your information, and submit. You will receive a tracking number. [VERIFY: docket ID]
  • By regular mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, P.O. Box 8016, Baltimore, MD 21244-8016. [VERIFY: address per rule ADDRESSES section]
  • By express/overnight mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.
  • Reference the rule: Identify the rule (CMS-1848-P) and the specific proposal (payment reduction for E/M services reported with modifier -25) at the top of your comment.
  • Make it yours: Form letters are counted; specific, data-backed comments from real practices are read. Include your specialty, practice size, and concrete examples of same-day care from your own patients.
  • Deadline: Comments must be received by September 14, 2026.
Sample comment (personalize before submitting)

Re: CMS-1848-P — CY 2027 Medicare Physician Fee Schedule Proposed Rule; proposed payment reduction for E/M services reported with modifier -25.

I am a [urologist / practice administrator / certified coder] at [practice name], a [number]-provider urology practice in [city, state]. I strongly oppose the proposal to apply a 50% multiple procedure payment reduction to significant, separately identifiable E/M services reported with modifier -25.

First, the 50% reduction far exceeds any actual resource overlap. By definition, an E/M reported with modifier -25 is payable only when the physician performs history, examination, and medical decision making beyond the pre- and post-service work already valued in the procedure. That physician work is not duplicated anywhere in the procedure payment. At most, a small amount of indirect practice expense (one check-in, one claim) is shared — nowhere near half the value of the visit.

Second, the proposal double-counts. Procedure work RVUs already incorporate adjustments reflecting potential same-day E/M overlap. Applying an additional 50% reduction without revaluing those procedures reduces payment twice for the same theoretical efficiency.

Third, patient access will suffer. Same-day evaluation and treatment spares patients — many of them elderly Medicare beneficiaries traveling long distances — a second appointment, and it lowers total cost to the program. This proposal creates a direct financial incentive to split care into two visits, increasing patient burden, delaying treatment, and raising Medicare spending on duplicate visits.

In my practice, approximately [X]% of office encounters appropriately combine a significant, separately identifiable E/M with a same-day procedure such as cystoscopy, bladder instillation, or therapeutic injection. [Add one or two sentences with a concrete patient example.]

I urge CMS not to finalize this proposal. If CMS nonetheless finalizes any reduction, it should be limited to the small, demonstrable overlap in indirect practice expense — far below 50% — and CMS should simultaneously correct the existing same-day E/M adjustments embedded in procedure work RVUs to avoid double-counting.

Thank you for your consideration.
[Name, credentials, practice, city/state]

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.

Most common services
  • 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
Documentation drivers (prevent denials)
  • 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
Coding patterns (high-level)
  • 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
Common denial causes
  • 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]