2025 Coding Compliance Changes
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This page is dedicated to the plethora of changes in our coding compliance realm. This is not an all-inclusive list of all the changes. For the sake of sheer length of reading, I have deferred to other resources who have already beautifully catalogued these changes.
2025 ICD-10-CM Changes
FY 2025 ICD-10-CM codes went into effect October 1, 2024. Significant code changes include 252 additions, 13 deletions, and 36 revisions. Most coding software, e.g., Encoder, have already uploaded the new changes. If you’re old school like me, you’re going to want to go to the back of the manual (Appendix B) where it lists in order, all of the pertinent changes by chapter. ASG created an in-depth look at all of the changes on their blog. You can download a copy of their complimentary e-book.
2025 CPT Changes
The AMA (American Medical Association) publishes its new release annually, typically in the last quarter of the calendar year. Changes go into effect January 1, the following year.
Changes for 2025 include:
- 420 overall updates in the CPT 2025 code set, including 270 new codes, 112 deletions, and 38 revisions.
- 17 new telemedicine codes (98000-98016) in the Evaluation and Management (E/M) section.
- 33 new codes in the Surgery section for autografts, arthroplasty, and other surgical procedures
As mentioned regarding ICD-10- CM, CPT also has an appendix that is set aside just for the delineation of CPT code changes. Most coding software will be updated automatically with the new information.
If you want a sneak peek before the manual comes out, you’re going to have to either peruse their 75-page RUC meeting minutes, or attend their online 2025 CPT and RBRVS Symposium, scheduled for November 20-22nd.
Some of the topics on the agenda will be:
- Telemedicine
- (17) New Codes in the E/M section
- Audio-video telemedicine visits for new and established patients
- New Patients (98000 – 98003)
- Established Patients (98004 – 98007)
- Audio-only telemedicine (new and established) will replace existing telephone-only codes
- New Patients (98008 – 98011)
- Established Patients (98012 – 98015)
- Brief communication technology-based service (e.g., virtual check-in)
- New CPT Code 98016 replaces G2012
- Audio-video telemedicine visits for new and established patients
- (17) New Codes in the E/M section
- Digital Medicine
- RTM was revised to include device supply for data access or data transmissions to support RTM of patients.
- Augmented/AI (Artificial Intelligence)
- Was given a new taxonomy (2023)
- (7) New Category III Codes
- Medical Chest Imaging (0877T – 0800T)
- Electrocardiogram Measurements (0902T – 0932T)
- IG (Image Guided) Prostate Biopsies (0898T)
- General Surgery
- Revisions regarding skin grafts and wound care and recovery
- Advancements in surgical techniques for elimination of abdominal tumors
Resources:
AAFP: Mixed Bag Article
Radiology: ACR Anticipated Code Changes
Radiology: MSN 2025 Anticipated Radiology CPT Code Changes
2025 MPFS Proposed Rule
Conversion Factor
(CF) of $32.35, which is about 2.8% below the current CF of $33.28
(CF) Anesthesia, proposed to be $20.3340, a 2.1% decrease from 2024.
Telehealth Changes
CMS proposes to allow distant site practitioners to use their currently enrolled practice location instead of their home address when providing telehealth services from their home.
Audio-only Technology
- Modifiers to indicate audio-only
- Definition of telecommunications to include audio-only
- Suspend frequency limitations for SHV, Critical Care Consultation, NF Visits
Resource: Shepherd Law Article
(APCM) Advanced Primary Care Management
- 3 New HCPCS Codes stratified by number of CCs
- Longitudinal Care
- Continuing Focal Point for ALL needed healthcare services
Resource: APCM Law Article
Overpayments
- Reporting – proposing 6-month investigatory period in addition to 180-day good faith investigation
- Repaying – if neither are performed in a timely matter, must repay in 60-days
G2211 proposed revision: (New CMS FACT Sheet)
CMS proposes to refine the current policy beginning CY 2025 with respect to the office/outpatient evaluation and management (O/O E/M) visit complexity add-on code by allowing payment when the O/O E/M base code is reported by the same practitioner on the same day as an annual wellness visit (AWV), vaccine administration, or any Medicare Part B preventive service furnished in the office or outpatient setting.
IP/OBS inherent complexity add-on code
- Inherent complexity IP/OBS setting
- Associated with a suspected or confirmed infectious disease
Caregiver Training revision
- New HCPCS Codes
- Focus on clinical skills
- Wound Care, infection control, medication management
- Goal – reduce complications and patient monitoring
ASCVD – Atherosclerotic Cardiovascular Disease risk assessment and risk management services
- Add-on code must be reported with E/M Service
- May include:
- BP Management
- Cholesterol Management, and
- Smoking Cessation
Global Surgery Package
Proposing strategies to improve payment accuracy
Expand use of transfer of care modifiers in Global Surgery Package
When a practitioner only plans to provide the pre-operative (-56), procedure only -55), or post-operative (-54) portions of the package.
PTA and OTA – in an outpatient private practice setting
Proposing supervision change from direct to general for OT therapy and certification of plan
Colorectal Cancer Screenings
- Remove Barium Enema coverage
- Add CTC (computed tomography colonography)
CMS would expand the definition of a complete CRC screening to include a follow-on colonoscopy after a positive result from a Medicare-covered blood-based biomarker test or non-invasive stool-based test. CMS also proposes that patients would not incur cost-sharing for the follow-on colonoscopy, which could improve access to care and cancer prevention.
Behavioral Health changes
New digital code (e.g., GMBT1) for supply of mental health treatment device and initial education and onboarding, per course of treatment that augments a behavioral therapy plan.
Medicare Physician Fee Schedule Resources
Stay tuned. The Medicare Physician Fee Schedule Final Rule should be published in the Federal Register sometime in the last quarter of this year. Hopefully, we will all have answers in early November. The AMA and CMS love to keep us waiting for the final reveal.