Additional Office and Outpatient Services Billed with Evaluation and Management (E&M)
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Governs Healthfirst reimbursement rules for Evaluation and Management (E&M) services, preventive medicine services, add-on complexity codes (e.g., G2211), and other office/outpatient services billed the same date of service for Healthfirst lines of business and participating/non-participating providers submitting CMS-1500/837P claims.
Expanded policy scope to include reimbursement guidance for additional office and outpatient services billed with Evaluation and Management (E&M) services and added new chapters for HCPCS G0545, preventive counseling and behavioral counseling services, medical nutrition therapy, prolonged services, screening services, and vision services.
Revised G2211 reimbursement policy for HARP, Essential Plan, and Qualified Health Plan to bundled reimbursement effective November 1, 2026.
Added NYS Medicaid pediatric coverage for HCPCS code G2211 for Medicaid members ages 0-20 with billing requirements including reporting G2211 with a qualifying E&M service, allowance for preventive medicine visit codes, limitation of one unit per patient per week, and eligible POS codes 02, 10, 11, and 22.
Added telehealth billing requirements clarifying G2211 is reimbursable via telehealth when billed in accordance with NYS Medicaid requirements and specifying telehealth modifiers (93 and 95).
Clarified that G2211 is not separately reimbursable for Adult Medicaid members age 21 and older and that claims submitted by in-network providers for adult Medicaid members will be denied.
Added Modifier 25 billing requirements and documentation standards for newly addressed services.
Coverage Criteria and Reimbursement Rules
Preventive + E&M coverage criteria
Rules governing payment when preventive medicine examinations are performed with problem-oriented E&M or other services.
G2211 (pediatric Medicaid) coverage criteria
G2211 reimbursement rules for Medicaid Managed Care (NYS) pediatric members:
G2212 coverage criteria
G2212 coverage and documentation requirements by line of business:
LOB payment
- For MMC, CHP, HARP, Essential Plan (EP), and QHP: G2212 is not separately reimbursable; reimbursement is inclusive and bundled into the primary E&M service.
- For Medicare Advantage, IB‑Dual, and CompleteCare (MAP): G2212 is eligible for separate reimbursement when reported with a qualifying E&M and supported by documentation that meets CMS requirements for prolonged services.
- For the SHP line of business: G2212 is not a covered benefit.
G0545 coverage criteria
G0545 coverage and documentation requirements by line of business:
LOB payment
- For MMC, CHP, HARP, EP, and QHP (effective Nov 1, 2026): G0545 is not separately reimbursable; reimbursement is inclusive and bundled into the E&M service.
- For Medicare Advantage, IB‑Dual, and CompleteCare (MAP): G0545 may be separately reimbursed when reported with a qualifying E&M and supported by documentation that meets applicable CMS coding and documentation requirements.
- For the SHP line of business: G0545 is not a covered benefit.
Preventive and behavioral counseling coverage
Preventive counseling and behavioral counseling coverage stance:
Preventive/behavioral counseling coverage rules
Preventive counseling and behavioral counseling services reimbursement rules by LOB:
MNT coverage rules
Medical Nutrition Therapy (MNT) reimbursement rules by LOB:
Prolonged services coverage rules
Prolonged services reimbursement rules by LOB:
Screening services coverage rules
Screening services reimbursement rules by LOB:
Vision screening coverage criteria
Coverage and reimbursement vary by line of business and billing context:
ANY of the following
G2211 and related service coverage criteria
Healthfirst coverage and billing criteria for G2211 and related services (partial — document continues in other parts).
Applicable CPT/HCPCS Codes and Pairing Rules
| G2211 | Complexity add-on; must be billed with E&M 99202-99205 or 99211-99215; must be billed same date as qualifying E&M; not standalone |
| G2212 | Prolonged service add-on; must be billed with E&M 99205 or 99215; only when total physician/qualified professional time exceeds maximum time threshold for primary E&M; not standalone |
| G0545 | Complexity add-on; must be billed with a qualifying E&M service; may not be reported as a standalone service |
| 0403T | Preventive counseling — considered inclusive to associated E&M or preventive medicine service (not separately reimbursable for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026) |
| 99401 | Preventive counseling — listed among codes considered inclusive; non-covered under Original Medicare (Healthfirst covers as supplemental benefit beginning CY2026 for eligible Medicare members) |
| 99404 | Preventive counseling — listed among codes considered inclusive; non-covered under Original Medicare (Healthfirst covers as supplemental benefit beginning CY2026 for eligible Medicare members) |
| 99406 | Tobacco cessation counseling — may be separately reimbursed for Medicare LOB when CMS criteria met |
| 99407 | Tobacco cessation counseling — may be separately reimbursed for Medicare LOB when CMS criteria met |
| G0396 | Smoking cessation counseling — may be separately reimbursed for Medicare LOB when CMS criteria met |
| G0397 | Smoking cessation counseling — may be separately reimbursed for Medicare LOB when CMS criteria met |
| G0443 | Behavioral counseling for obesity — may be separately reimbursed for Medicare LOB when CMS criteria met |
| G0445 | Behavioral counseling to prevent STIs — may be separately reimbursed for Medicare LOB when CMS criteria met |
| G0446 | Behavioral counseling for intensive alcohol misuse — may be separately reimbursed for Medicare LOB when CMS criteria met |
| 0403T, 99401, 99404, 99406, 99407, 99408, 99409, 99411, 99412, G0296, G0396, G0397, G0443, G0445, G0446, G0473, G2011, H0005, S0257, S9470 | Preventive counseling and behavioral counseling codes considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; not separately reimbursable unless otherwise specified |
| 99401 | Non-covered under Original Medicare; covered as supplemental benefits by Healthfirst beginning CY2026 for eligible Medicare members |
| 99404 | Non-covered under Original Medicare; covered as supplemental benefits by Healthfirst beginning CY2026 for eligible Medicare members |
| H0005 | Not covered under Medicare Advantage lines per this policy excerpt |
| S0257 | Not covered under Medicare Advantage lines per this policy excerpt |
| 97802 | Medical Nutrition Therapy — considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; not separately reimbursable |
| 97803 | Medical Nutrition Therapy — considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; not separately reimbursable |
| 97804 | Medical Nutrition Therapy — considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; not separately reimbursable |
| G0270 | MNT evaluation and management — considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; not separately reimbursable |
| G0271 | MNT follow-up — considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; not separately reimbursable |
| S9470 | Education and training — may be separately reimbursed for Medicare lines when CMS criteria are met; considered inclusive for MMC/CHP/HARP/EP/QHP |
| 99415 | Prolonged service — considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; not separately reimbursable |
| 99416 | Prolonged service — considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; not separately reimbursable |
| 99417 | Prolonged service — considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; not separately reimbursable |
| 99418 | Prolonged inpatient/observation E/M service — referenced as prolonged service; may be non-covered for some LOBs per policy excerpt |
| G0102 | Prostate cancer screening; considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; may be separately reimbursed for Medicare Advantage/IB-Dual/CompleteCare/SHP when CMS criteria met |
| Q0091 | Screening Papanicolaou smear; obtaining, preparing and conveyance of specimen; considered inclusive to associated E&M or preventive medicine service for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; may be separately reimbursed for Medicare Advantage/IB-Dual/CompleteCare/SHP when CMS criteria met |
| 99172 | Visual function screening (automated or semi-automated) — considered inclusive for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; may be separately reimbursed for Medicare-related LOBs when CMS criteria are met; not covered for SHP |
| 99173 | Screening test of visual acuity, quantitative, bilateral — considered inclusive for MMC/CHP/HARP/EP/QHP effective Nov 1, 2026; may be separately reimbursed for Medicare-related LOBs when CMS criteria are met; not covered for SHP |
| 99418 | Prolonged inpatient/observation E/M service, each 15 minutes beyond primary service |
| G0102 | Prostate cancer screening; digital rectal examination |
| Q0091 | Screening Papanicolaou smear; obtaining, preparing and conveyance of specimen |
| 99173 | Screening test of visual acuity, quantitative, bilateral |
| G2211 | Office/outpatient visit complexity add-on code (visit complexity) |
Provider Billing, Documentation, and Compliance Actions
Bill preventive exam and E&M together; use Modifier 25 and support with documentation
When both a preventive medicine examination and an E&M service are performed on the same date of service, bill both on the same claim and append Modifier 25 to the E&M. Documentation must support that the E&M is significant and separately identifiable from the preventive exam and justify the level of E&M billed and medical necessity for the additional service.
- Bill preventive medicine exam and E&M on same claim.
- Append Modifier 25 to the E&M service.
- Maintain documentation that distinguishes preventive vs problem‑oriented services and supports the E&M level and medical necessity.
Denial risks when documentation or Modifier 25 justification is insufficient
An E&M service may be denied if the medical record does not support a separate and distinct service, if the E&M duplicates routine preventive components, or if Modifier 25 is appended without sufficient justification.
- Denial risk when documentation fails to show a significant, separately identifiable E&M.
- Denial risk when E&M duplicates preventive visit components.
- Denial risk when Modifier 25 lacks sufficient justification in the record.
Only bill add-on codes with qualifying E&M; not as standalone
Add-on codes (e.g., G2211, G2212, G0545) must be reported only with their qualifying E&M codes per the policy pairing rules and may not be billed as standalone services.
- G2211 must be reported with E&M 99202–99205 or 99211–99215 and billed same date as the qualifying E&M.
- G2212 must be reported with E&M 99205 or 99215 and only when total provider time exceeds the primary E&M maximum threshold.
- G0545 must be reported with a qualifying E&M service and not billed standalone.
Adhere to LOB-specific billing and CMS/NYS Medicaid requirements
Follow line-of-business–specific coding, billing, and documentation requirements: NYS Medicaid pediatric guidance applies to G2211 for ages 0–20; Medicare lines follow CMS coverage and documentation rules and some LOBs do not allow separate reimbursement.
- G2211 reimbursable for Medicaid members ages 0–20 per NYS Medicaid; limited provider types and POS/telehealth rules apply.
- G2212 and G0545 may be bundled (not separately reimbursable) for MMC/CHP/HARP/EP/QHP; Medicare Advantage/IB‑Dual/CompleteCare may reimburse separately when CMS requirements are met.
- Some LOBs (e.g., SHP) list these codes as not covered.
Comply with applicable coding, billing, and documentation requirements
Providers must report services in compliance with all applicable coding, billing, and documentation requirements referenced by Healthfirst, CMS, and state and federal guidance.
- Ensure claims conform to applicable NCCI edits, LCD/NCD, CMS guidance, and Healthfirst policy.
- Maintain required documentation to support coding and billing decisions.
Medicare Advantage: confirm CMS criteria before billing select counseling codes separately
Certain preventive/behavioral counseling and related CPT/HCPCS may be separately reimbursed for Medicare Advantage/related lines when CMS coverage criteria, coding, documentation, and benefit requirements are met; confirm CMS criteria before billing separately.
MNT codes: Medicare may reimburse separately when CMS criteria met; bundled for many Medicaid/Marketplace LOBs
Medical Nutrition Therapy codes (CPT/HCPCS 97802–97804, G0270, G0271, S9470) may be separately reimbursed for Medicare Advantage/IB‑Dual/CompleteCare when CMS coverage, coding, and documentation requirements are met; otherwise these codes are inclusive for MMC/CHP/HARP/EP/QHP.
- For Medicare lines, ensure documentation meets CMS requirements before billing MNT codes separately.
- For MMC/CHP/HARP/EP/QHP (effective Nov 1, 2026), these MNT codes are bundled into the associated E&M or preventive service.
Vision screening (99172/99173) bundled for most LOBs effective Nov 1, 2026; Medicare lines may differ
For MMC, CHP, HARP, EP, and QHP (effective Nov 1, 2026) CPT codes 99172 and 99173 are considered inclusive to the associated E&M or preventive medicine service and are not separately reimbursable; Medicare-related lines may reimburse separately when CMS criteria and benefit requirements are met.
Maintain documentation sufficient to support billed services and modifiers
Providers must maintain documentation sufficient to support billed services and comply with all applicable Healthfirst, CMS, state, and federal billing requirements.
- Documentation must support that services billed are medically necessary and justify modifiers or add‑on codes.
- Retain records that clearly distinguish preventive services from problem‑oriented services.
Bill G2211 only with qualifying E&M; pediatric NYS Medicaid rules include 1 unit/week and telehealth modifiers
Report HCPCS G2211 only with a qualifying E&M service; preventive medicine visit codes are permitted with G2211 for NYS Medicaid pediatric members, limit one unit per patient per week, and append required telehealth modifiers (93 or 95) for telehealth services.
G2211 is not separately reimbursable for adult Medicaid members (age 21+); claims will be denied
G2211 is not separately reimbursable for Medicaid members age 21 years and older; claims submitted by in‑network providers for adult Medicaid members will be denied.
Report services in compliance with applicable coding, billing, and documentation requirements
Providers are expected to report services in compliance with applicable coding, billing, and documentation requirements; this is an overarching expectation across the policy.
- Follow Healthfirst, CMS, state, and federal billing rules when selecting codes, modifiers, and submitting documentation.
- Claims are subject to adjudication per NCCI, LCD/NCD, and Healthfirst policies.
Definitions and Code Descriptions
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