Decoding G2211: when to use the add-on code
A family physician recently asked “Can I report an E/M service, G2211, and venipuncture at the same visit? Is modifier 25 required on the venipuncture code?”
Rules to consider
Before we get to the answer, let’s review the definition of code G2211:
Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient's single, serious condition or a complex condition. (Add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established.)
Physicians can add G2211 to office E/M codes (99202-99205 or 99211-99215) and home and residence E/M codes (99341, 99342, 99344, 99345, 99347, 99348, and 99350) to indicate that they have a long-term relationship with the patient and “serve as the continuing focal point for all needed health care services.” The Centers for Medicare & Medicaid Services (CMS) emphasizes that it isn’t about the condition being treated but the longitudinal relationship with the patient.
In general, CMS does not allow G2211 when modifier 25 is appended to the E/M code. For example, if a physician removed a lesion on the same day of an office visit and added modifier 25 to the E/M code to indicate it was separate from the lesion removal, G2211 could not be reported. The exception involves Medicare-covered preventive services, such as Part-B preventive services, annual wellness visits (AWVs), or immunization administrations. G2211 may be reported alongside an office or outpatient E/M code that has modifier 25 appended provided the separately reported same-day service is a Medicare-covered preventive service.
If an E/M visit includes venipuncture (code 36415), there is not a National Correct Coding Initiative (NCCI) edit for this, meaning Medicare does not have a rule prohibiting the codes from being billed together. Venipuncture isn’t paid under the Medicare Physician Fee Schedule; it is paid under the Clinical Laboratory Fee Schedule. Therefore, for Medicare claims, it isn’t necessary to add append modifier 25 to the E/M code when venipuncture is performed on the same day. Commercial payers may have an edit that requires modifier 25 on an E/M visit with venipuncture, but it is not an NCCI edit.
The answer
Back to the physician’s question, if venipuncture is performed on the same day as an E/M office visit, can add-on code G2211 be used? Yes. Is modifier 25 required on the venipuncture code. No.
Note: In July 2026, CMS proposed replacing G2211 with two modifiers, one for ACO participants and one for non-ACO participants. If they move forward with that proposal, the modifiers will be released in early November and effective January 2027.
— Betsy Nicoletti, speaker and consultant in coding education, billing, and accounts receivable
For further reading, see “G2211 Update and Infographic: When to Use the Visit Complexity Add-On Code.”