Coding & Modifiers

Guide

Can You Bill an E/M With Modifier 25 on an Orthopedic Injection Day?

Can You Bill an E/M With Modifier 25 on an Orthopedic Injection Day?

Can You Bill an E/M With Modifier 25 on an Orthopedic Injection Day?

Medicare rules, payer policies and a scenario table for billing a same-day E/M with modifier 25 alongside knee, shoulder and hip injections.

Medicare rules, payer policies and a scenario table for billing a same-day E/M with modifier 25 alongside knee, shoulder and hip injections.

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12 min read

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Sources cited: 19

Doctor examining a patient's leg during an orthopedic office visit

Short answer

Yes, but only when the visit includes a significant, separately identifiable evaluation beyond the usual pre-injection assessment. Injection codes such as 20610 carry a 0-day global period, so Medicare treats the decision to inject as part of the procedure. Append modifier 25 to the E/M only when the documented work, such as a new problem’s work-up, stands alone.

Yes, but only when the visit includes a significant, separately identifiable evaluation beyond the usual pre-injection assessment. Injection codes such as 20610 carry a 0-day global period, so Medicare treats the decision to inject as part of the procedure. Append modifier 25 to the E/M only when the documented work, such as a new problem’s work-up, stands alone.

Key takeaways

  • Injection codes such as 20610 include the decision to inject; a same-day E/M needs significant, separately identifiable work beyond that decision.

  • Different diagnoses are not required, and new-patient status alone does not justify a same-day E/M.

  • A scheduled repeat injection with a brief check-in usually supports only the injection code.

  • Document the E/M and the procedure separately so the visit stands on its own if audited.

  • CMS proposed paying the lower-valued same-day service at 50% starting in 2027; as of October 2026 it is not final.



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Official Medical Fee Schedule: RVUs adjusted by county GPCIs, times a California conversion factor

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Delayed






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Record the employer’s name and address, the date of injury, and the body parts and mechanism of injury in the patient’s words.

Confirm with the adjuster that the claim is open and which body parts are accepted; note the adjuster’s name, phone number and the date.

On a typical orthopedic clinic day, a patient with knee osteoarthritis, a painful shoulder or an arthritic hip is examined and receives a joint injection at the same visit. The billing question is whether that visit is a separately payable evaluation and management (E/M) service with modifier 25, or whether its payment is already built into the injection code.

The answer depends on Medicare’s global surgery rules, the note and each payer’s policy. It also carries compliance weight: same-day E/M billing with minor procedures has drawn Office of Inspector General (OIG) reviews since 2005, and CMS proposed a payment cut for these visits in July 2026. This guide covers the rules as of October 2026.

What do joint injection codes 20600–20611 cover?

CPT codes 20600 through 20611 describe drawing fluid out of a joint or bursa, injecting medication into it, or both, grouped by joint size and by whether ultrasound guidance is used:

Code

What it describes (paraphrased)

20600

Small joint or bursa, such as a finger or toe, without ultrasound guidance

20604

Small joint or bursa with ultrasound guidance, saved image and report

20605

Intermediate joint or bursa, such as the wrist, elbow, ankle or AC joint, without ultrasound

20606

Intermediate joint or bursa with ultrasound guidance, image and report

20610

Major joint or bursa, such as the knee, hip, shoulder or subacromial bursa, without ultrasound

20611

Major joint or bursa with ultrasound guidance, image and report

Three billing details matter. Medicare’s fee schedule assigns 20610 a 0-day global period, which makes it a minor procedure. The NCCI Policy Manual counts one unit per joint, including its surrounding bursae, so aspirating a shoulder and two of its bursae is one unit of 20610. And for Medicare, the injection code does not include the drug other than local anesthetic; when your practice buys the drug, report it with its HCPCS Level II code.

Why is the decision to inject already paid for?

Every procedure on the Medicare Physician Fee Schedule has a global indicator. Procedures with a 0- or 10-day global period are minor procedures, and their payment covers the usual pre-procedure work, including the evaluation that leads to the procedure. That is the core of the global surgical package.

The NCCI Policy Manual (Chapter I, Section D, and Chapter IV, Section B, revised January 1, 2026) says the decision to perform a minor procedure is included in its payment and must not be reported as a separate E/M. The Medicare Claims Processing Manual adds that the initial evaluation is always included in a minor procedure’s allowance. Its example is a scalp laceration: a visit is billable if a full neurological exam is needed for head trauma, but not if the physician only decides sutures are needed and checks allergy and immunization status.

The decision to inject is part of the injection. A same-day E/M is billable only when the note documents significant, separately identifiable work beyond that decision.

Major procedures follow a different rule. An E/M on the day of or the day before a 90-day global surgery that results in the decision to operate is billed with modifier 57. Modifier 57 does not apply to injections or other 0- and 10-day procedures, and Medicare contractors do not pay it there.

What makes an E/M “significant and separately identifiable”?

Medicare pays a same-day E/M when the physician documents a significant, separately identifiable service above and beyond the procedure’s usual pre- and post-procedure work (Claims Processing Manual, Chapter 12, §30.6.6.B). NCCI frames it as an E/M unrelated to the decision to perform the procedure. On injection days, that usually means one of three things:

  • A separate problem is evaluated and managed, such as new hip pain in a patient scheduled for a shoulder injection.

  • A new or changed problem gets a real work-up: a differential diagnosis, imaging or labs ordered or reviewed, and a plan that goes beyond the injection.

  • A management decision outside the injection is made, such as evaluating surgical candidacy, starting physical therapy or prescribing a brace.

Different diagnoses are not required; the E/M and the injection can share a diagnosis code when the E/M work is genuinely separate. AAPC’s advice is to document the two services separately and report the E/M only if it stands on its own.

Level the E/M on the separate work alone. The pre-injection assessment belongs to the injection, so it should not count toward medical decision making, and if you select the level by time, leave out the minutes spent on the procedure.

Does a new patient visit change the answer?

Medicare defines a new patient as one who has not received a face-to-face professional service from the physician, or a same-specialty physician in the same group, in the previous three years (Claims Processing Manual §30.6.7.A). New patients often arrive with undiagnosed problems, so their visits frequently include work beyond the injection decision.

Status alone does not justify an E/M, though. NCCI says being new is not enough by itself, and Medicare’s global rules bar billing the decision to perform the procedure for new and established patients alike. A patient referred to inject an already-diagnosed problem, with a brief assessment, usually supports the injection code alone.

When can you bill an E/M with a knee, shoulder or hip injection?

The table applies Medicare rules to common injection visits. Use it as a starting point; the chart decides each case.

Scenario

Bill E/M + 25?

Why

New patient, new knee pain: history, exam, X-ray review, differential diagnosis and therapy plan, then 20610

Often yes

A new problem’s work-up can stand apart, but only work beyond the decision to inject counts

New patient referred to inject known knee osteoarthritis; brief check, then 20610

Usually no

The assessment is the decision to inject; new-patient status alone is not enough

Scheduled repeat knee or shoulder injection; brief interval check

No

The pre-injection assessment is part of the 0-day global payment

Scheduled shoulder injection; new hip pain examined, imaged and given a plan

Yes

A separate problem was evaluated and managed

Scheduled knee injection, but the knee is now hot and swollen; evaluated for infection or gout and aspirated for fluid analysis

Often yes

The changed presentation needs a work-up beyond the planned procedure

Surgeon evaluates the hip and recommends a total hip replacement for a later date, then does an ultrasound-guided injection (20611)

Often yes

The surgical evaluation goes beyond the injection; modifier 57 does not apply because surgery is not today or tomorrow

Patient in the global period of an unrelated right knee arthroscopy has a new left shoulder problem evaluated and injected

Yes, with 24 and 25

The E/M takes modifiers 24 and 25; the injection takes modifier 79

The last row trips up many practices. CMS’s global surgery booklet calls for both modifiers 24 and 25 when a separately identifiable E/M on a procedure day falls within another procedure’s postoperative period, and Medicare denies a procedure with its own global period performed in that window unless it carries modifier 58, 78 or 79.

What documentation supports modifier 25?

Medicare does not require records with the claim, but both the E/M and the procedure must be documented well enough to support each service on review (Claims Processing Manual §30.6.6.B). A contractor that finds high modifier 25 use can review records case by case, educate the practice and then impose prepayment screens or documentation requirements. A defensible chart usually has:

  • A distinct E/M section: the reason for the separate evaluation, pertinent history and exam, and the decision making for that problem.

  • Evidence of work beyond the injection decision, such as a differential diagnosis, tests ordered or reviewed, and treatment other than the injection.

  • A separate procedure note: joint and side, indication, consent, drug and dose, a saved ultrasound image when 20604, 20606 or 20611 is billed, and how the patient tolerated it.

  • Diagnosis codes linked to the services they support.

  • Patient-specific wording, not cloned text repeated at every visit.

When a payer bundles the E/M into the injection, the remittance often shows CARC CO-97, meaning the service’s payment is included in another service already processed. If the note shows separate work, appeal with the records. If not, the denial is correct and the fix is provider education. Our guide to common orthopedic claim denials covers other patterns.

Why is same-day E/M billing an audit focus?

OIG has examined same-day E/M billing with minor procedures for two decades:

  • Its 2005 report Use of Modifier 25 (OEI-07-03-00470) found that 35% of modifier 25 claims Medicare allowed in 2002 did not meet program requirements, about $538 million in improper payments.

  • A May 2025 audit of E/M services billed with eye injections (A-09-23-03014) found that documentation for 22 of 24 sampled services did not support modifier 25. CMS followed with a February 2026 MLN reminder that the decision to perform a minor procedure is part of the procedure.

  • A November 2025 dermatology audit (A-04-21-04083) found that 90 of 100 sampled E/M services met requirements; OIG still recommended more oversight.

  • In March 2026, OIG added a Work Plan review of E/M services paid on the same day as minor surgery without modifier 25, covering 2023–2025 claims (OAS-26-04-028).

The recent audits focused on eye injections and dermatology, but the rule they applied also governs 20610: the assessment that leads to a minor procedure is part of the procedure.

How do commercial payers handle modifier 25?

Commercial payers share the concept but differ on edits, records requests and payment. Policies we reviewed, as of October 2026:

Payer

Policy

What it says

UnitedHealthcare (commercial and Individual Exchange)

Global Days Policy, Professional, 2026R0005E (version dated September 20, 2026)

A 0-day global includes that day’s E/M; append 25 for a significant, separately identifiable E/M; different diagnoses not required; same-specialty physicians under one tax ID count as one physician

Cigna Healthcare (commercial)

Reimbursement Policy M25 (effective April 20, 2009; last updated February 20, 2026)

The E/M must address a new or distinct problem; with a scheduled procedure, an E/M is warranted only if a new or significant separate problem arises; records required with the claim for certain NCCI edits

Blue Cross Blue Shield of Michigan and Blue Care Network

Modifier 25 reimbursement policy announced February 2026

Would have paid E/M codes 99202–99205 and 99212–99215 billed with 25 alongside a 0- or 10-day procedure at 50% from May 1, 2026; paused April 15, 2026

Cigna twice announced, in 2022 and 2023, that it would require records with every E/M 99212–99215 billed with modifier 25 and a minor procedure, and delayed it both times. Other plans, including Aetna and other Blue plans, publish their own rules, and contracts can override policies, so confirm current versions before setting claim edits.

Can you add G2211 on an injection day?

HCPCS G2211, Medicare’s visit complexity add-on, is not paid when its office or outpatient E/M base code carries modifier 25, unless the other same-day service is an annual wellness visit, a vaccine administration or another Part B preventive service (CMS booklet MLN006764, May 2026). A joint injection is not one of those exceptions. CMS has also proposed replacing G2211 with a payment modifier for 2027, so recheck after the final rule.

What would the CY2027 proposal change?

In the CY2027 Physician Fee Schedule proposed rule (CMS-1848-P, released July 14, 2026; comments closed September 14, 2026), CMS proposed reducing payment when the same physician, or a physician in the same group practice, furnishes a separately identifiable office or outpatient E/M visit on the same day as a procedure with a 0-, 10- or 90-day global period. The higher-paid service would be paid at 100% and the other same-day services at 50%. CMS said it sees efficiencies when a visit and a global procedure happen together and that current payment is likely duplicative.

As of October 2026 this is a proposal, not a final policy. If finalized as proposed, it would apply from January 1, 2027, and the lower-paid of an E/M with modifier 25 and a 20610 would be paid at half. The coding rules above would not change: the E/M would still need to be significant and separately identifiable. See our CY2027 fee schedule overview for the rest of the proposed rule.

How Rette helps

Rette’s agents read the clinical and procedure notes in the EHR your practice already uses, such as athenahealth, Epic or eClinicalWorks, and suggest codes for your coders to review. They validate claims against NCCI, NCD and LCD rules before submission and bring related denials and appeals into one prioritized work queue.

Frequently asked questions

Do the E/M and the injection need different diagnosis codes?

No. The Medicare Claims Processing Manual and the NCCI Policy Manual both state that different diagnoses are not required, and the UnitedHealthcare and Cigna policies say the same. What matters is whether the E/M work is separate from the injection. A shared diagnosis such as knee osteoarthritis is acceptable when the note shows a separate evaluation, while adding a second diagnosis does not rescue an E/M that only covered the decision to inject.

Can modifier 57 be used instead of modifier 25 on an injection day?

No. Modifier 57 identifies an E/M that results in the decision to perform a major procedure with a 90-day global period, on the day of or the day before surgery. Medicare contractors do not pay modifier 57 on visits tied to 0- or 10-day procedures such as joint injections, so a separately identifiable visit on injection day takes modifier 25 instead.

Does ultrasound guidance change whether the E/M is billable?

No. Ultrasound guidance is part of the procedure described by 20604, 20606 or 20611, not part of the visit, so it adds nothing to the E/M side of the decision. The same question applies: was there significant, separately identifiable work beyond the decision to inject? Check each code’s global indicator in Medicare’s Physician Fee Schedule Look-Up Tool; a 000 or 010 indicator means the minor-procedure rules apply.

Will Medicare pay less for E/M visits with modifier 25 in 2027?

Possibly. In July 2026, CMS proposed paying the higher-valued service at 100% and other same-day services at 50% when the same physician or group furnishes a separately identifiable office or outpatient E/M on the same day as a 0-, 10- or 90-day global procedure. As of October 2026 the policy is not final. CMS will announce its decision in the CY2027 final rule, which would apply to dates of service starting January 1, 2027.

What should we do when a payer denies the E/M as included in the injection?

Start with the note. If it documents a separate problem or a work-up beyond the decision to inject, appeal with the records and point to the separate history, exam and decision making. If the note shows only the pre-injection assessment, the denial is correct; adjust the balance according to your contract and use the case to coach the provider. Track these denials by provider so patterns surface before an auditor finds them.

Sources

  1. Medicare NCCI Policy Manual, Chapter I: General Correct Coding Policies — CMS, revision date January 1, 2026

  2. Medicare NCCI Policy Manual, Chapter IV: Surgery: Musculoskeletal System, CPT Codes 20000–29999 — CMS, revision date January 1, 2026

  3. Medicare Claims Processing Manual, Chapter 12: Physicians/Nonphysician Practitioners — CMS, Rev. 13753, issued May 7, 2026

  4. Global Surgery (MLN907166) — CMS Medicare Learning Network, December 2025

  5. Evaluation and Management Services (MLN006764) — CMS Medicare Learning Network, May 2026

  6. Evaluation and Management Services & Intravitreal Injections: Bill Correctly — CMS Medicare Learning Network, February 12, 2026

  7. Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule — CMS fact sheet, July 14, 2026

  8. Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies (CMS-1848-P) — Federal Register, 91 FR 43842, July 16, 2026; comments closed September 14, 2026

  9. 2027 Medicare Physician Payment Schedule and Quality Payment Program Proposed Rule Summary — American Medical Association, July 2026

  10. Use of Modifier 25 (OEI-07-03-00470) — HHS Office of Inspector General, November 2005

  11. Medicare Payments for Evaluation and Management Services Provided on the Same Day as Eye Injections Were at Risk for Noncompliance With Medicare Requirements (A-09-23-03014) — HHS Office of Inspector General, May 27, 2025

  12. Dermatology Providers Generally Met Medicare Requirements for Evaluation and Management Services Performed on Same Day as Minor Surgical Procedures (A-04-21-04083) — HHS Office of Inspector General, November 18, 2025

  13. Evaluation and Management Services on Same Day as Minor Surgery With No Modifier 25 (OAS-26-04-028) — HHS OIG Work Plan, announced March 16, 2026

  14. Problem Code: 20610 — AAPC, June 1, 2014

  15. Global Days Policy, Professional (Policy Number 2026R0005E) — UnitedHealthcare Commercial and Individual Exchange, version dated September 20, 2026

  16. Reimbursement Policy M25: Modifier 25 — Cigna Healthcare, effective April 20, 2009; last updated February 20, 2026

  17. Update: Clarification to policy update on E/M codes appended with modifier 25 — Blue Cross Blue Shield of Michigan, posted February 26, 2026; updated April 15, 2026

  18. New modifier 25 policy implementation paused — Blue Cross Blue Shield of Michigan, April 15, 2026

  19. Claim Adjustment Reason Codes — X12, CARC 97 last modified July 1, 2017

This guide is educational and is not legal, coding-compliance or billing advice. Payer rules change often, so confirm requirements with the payer before you bill. CPT® is a registered trademark of the American Medical Association; code descriptions here are Rette’s plain-language summaries.

See how Rette catches orthopedic denials before claims go out

See how Rette catches orthopedic denials before claims go out

See how Rette catches orthopedic denials before claims go out

Rette reads the operative note in the EHR you already use, suggests codes and checks claims against payer and NCCI rules before submission.