2025 Coding Update for G2211 and Case Study

It is important to stay up to date on proper and improper utilization of new, deleted and revised codes.  In review of 2025 an important revision occurred for G2211. This HCPCS code was first introduced in January 2024. G2211 is an add on code developed to communicate the patient has complex conditions and require longitudinal services. The intent was for primary care and specialists who determined through medical necessity the need for closer follow-up due to the chronic condition and need for longitudinal services or immediate continued care.  The code has now been revised in 2025 by CMS to include the scenario of evaluating an office visit but now being able to utilize the modifier 25 which means a distinct and separate procedure can be added to the visit. CMS has outlined these services which are covered by Part B medical services to include annual wellness visits, vaccinations or other procedures or preventive services (Centers for Medicare & Medicaid Services, 2025).  Previously a modifier 25 could not be utilized, which then prevented the patient from having additional services to optimize their point of access to receive as much care as they needed.  Now CMS has updated their regulations to allow specific part B-covered preventive service CPT/HCPCS codes on the same date of service as the Evaluation and Management services.

Note that the example provided here reflects a serious/high risk medical condition, G2211 can be utilized for many situations where the gastroenterologist is the “primary” provider for the patient’s specialty condition, with a longitudinal condition, reflected by a follow up plan for a future visit.  Thus, many patients with stable GERD, IBS etc. are eligible to have G2211 reported; or situations where the medical condition might be recommended to “follow up PRN” but where the patient is advised to return for colonoscopy screening at time-definite and is entered into a recall system.  This reflects continuity of care. 

Example:

SUBJECTIVE

Chief Complaint:

“Here for cirrhosis follow-up and weight management.”

History of Present Illness:

• 58-year-old male with compensated cirrhosis (Child‑Pugh Class A) due to alcohol use disorder; abstinent; no encephalopathy or ascites. Former hospital admission 2 years ago for variceal bleed; awaiting endoscopy follow-up.
• Comorbid: hypertension (on lisinopril), obesity (BMI 32).
• Reports stable energy, denies abdominal pain, confusion, or edema. Admits mild fatigue. Continues low-sodium, moderate-protein diet. Weighing weekly at home.
• Motivated to lose 10–15 lbs. interested in behavioral and nutritional support.

Objective

Vitals: BP 132/78, HR 78, RR 16, Temp 98.4°F, BMI 32, Weight 220 lbs. (lost 3 lbs. since last visit).

Physical Exam:

• Well‑appearing, NAD; non-jaundiced.
• Abdominal: soft, non-tender, no hepatomegaly, no shifting dullness.
• Extremities: no edema or asterixis.
• Neuro: alert, appropriate, no encephalopathy.

Labs:

• AST/ALT: 45/48 (stable); Alkaline Phosphatase 98, Bilirubin 1.2, Albumin 3.8, INR 1.1.
• Platelets 90K, CBC otherwise WNL.
• Recent MELD = 9.

Imaging/Procedures:

• Ultrasound (last month): nodular margins, no defects, no ascites.
• Upper endoscopy pending for varices surveillance.

Assessment

1. Compensated cirrhosis (Cirrhosis, no decompensation) – stable.
2. Hypertension – well-controlled.
3. Obesity, BMI 32 – secondary contributor to NAFLD & portal hypertension risk, not at goal.
4. Alcohol abstinence – maintained per patient.

Plan

Cirrhosis Management

• Continue routine labs q3-4 months (CBC, LFTs, INR).
• Schedule variceal surveillance endoscopy (~6‑12 months).
• Maintain abstinence – offer support services.
• Discuss hepatocellular carcinoma screening (US ± AFP q6 months).

Obesity & Lifestyle Counseling (G0447)

• Performed 15‑minutes of structured behavioral counseling:
• Goal: 5–7% weight loss in 6 months via Mediterranean-style diet and 150+ min/week moderate exercise.
• Reviewed glucose control and alcohol avoidance.
• Encouraged mindfulness and dietary tracking.
• Document session as G0447—distinct from E/M.

Ongoing Specialist Care (G2211)

• As hepatologist/gastroenterologist, serving as continuing focal point for compensated cirrhosis care — planning labs, imaging, variceal surveillance, and nutritional counseling—ongoing complexity, longitudinal relationship

Documentation of Services

• 99214‑25:
• Significant and separately identifiable E/M performed for cirrhosis follow-up (history, exam, moderate‑complexity decision making).
• Evaluation and plan exceed usual baseline service, not “at goal” for weight and metabolic control.
• Modifier 25 justified by distinct, robust counseling services.
• G2211 (add-on):
• Reflecting complexity inherent in longitudinal cirrhosis management — serious liver condition under specialist oversight
• Not billed with 99214‑25 due to CMS edits unless accompanied by preventive service (OK with G0447, which qualifies as preventive).
• G0447:
• 15 min of separate obesity counseling focused on weight loss strategy; documented duration and individualized plan.

Final Codes to Submit

• 99214‑25 Cirrhosis follow-up, diuretics and surveillance planning
• G2211 Complexity add-on — longitudinal cirrhosis care
• G0447 Obesity counseling, 15 min

Documentation Tips

• 99214‑25: note appropriate HPI, exam, labs, diagnostic reasoning, and moderate level medical decision making.
• G2211: mention longitudinal relationship, continuous oversight, and cognitive load of managing cirrhosis.
• G0447: include counseling duration, specific behavioral strategies, weight tracking, and patient goals.

References:

1. Centers for Medicare & Medicaid Services. (2025) CMS Transmittal 13199, https://www.cms.gov/files/document/r13199otn.pdf-0#page=9
2. Center for Medicare & Medicaid Services (2025). How to Use the Office & Outpatient Evaluation and Management Visit Complexity Add-on Code G2211.  https://www.cms.gov/files/document/mm13473-how-use-office-and-outpatient-evaluation-and-management-visit-complexity-add-code-g2211.pdf

Jill Olmstead, DNP, ANP-BC, CDIP, CCS-P, FAANP
Dr. Olmstead is an Adult Nurse Practitioner at Providence Health in Fullerton, California, with over 15 years of experience specializing in gastroenterology. She is a former member of the ASGE Reimbursement Committee and currently serves on the ASGE Advanced Practice Providers (APP) Committee. Dr. Olmstead has also represented the American Nurses Association as a Primary Delegate to the AMA CPT Editorial Panel, Health Care Professionals Advisory Committee (HCPAC).

Glenn D. Littenberg, MD, FASGE, MACP
Dr. Littenberg is a GI and Hepatology specialist and health policy expert with decades of leadership in practice management, coding, and reimbursement. Dr. Littenberg began with his solo practice, expanding to a group of four and served as founding board member and past Chief Medical Officer of inSite Digestive Healthcare now Unio Genesis Healthcare Partners. He currently serves as an Alternate CPT Advisor for ASGE. He has served on the AMA CPT Editorial Panel, chaired key ASGE committees including Practice Management and Reimbursement Committees. He has held numerous leadership roles within ASGE.