2025 Coding Compliance Changes

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) 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 (Telemedicine and Non-Face-to-Face Chart (internal link)
  • (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)
      • CAUTION:  CMS is not recognizing these CPT codes. How will we report these? E/M? There are specific requirements for Medicare patients (1) audio-only services (-93 modifier) and (2) provider must have A/V even if patient doesn’t or declines video.
    • Brief communication technology-based service (e.g., virtual check-in)
      • New CPT Code 98016 replaces G2012
      • This is the only new CPT code for telemedicine CMS is recognizing
• 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 (Note: Congress is voting on this 12/20/2024)

CMS proposed (finalized) 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

• Modifier (-93) to indicate audio-only (Use appropriate E/M for setting)
• Definition of telecommunications to include audio-only
• Suspend frequency limitations for SHV, Critical Care Consultation, NF Visits
• CMS is not recognizing new AMA E/M CPT codes for A/V or Audio-Only Telemedicine 

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 (G0545)

• Inherent complexity IP/OBS setting
• Associated with a suspected or confirmed infectious disease

Caregiver Training revision

• New HCPCS Codes (G0541 – G0543)
  • Approved as a telehealth service
  • At-A-Glance Chart (internal link)
• New Behavioral HCPCS Codes – Caregiver Training
• 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 (G0552) for supply of mental health treatment device and initial education and onboarding, per course of treatment that augments a behavioral therapy plan.

CMS also released six new Interprofessional/Internet/EHR codes for Behavioral Health professionals. At-A-Glance Chart (Internal Link)

Medicare Physician Fee Schedule Resources

Proposed Rules

Federal Register

AAFP Executive Summary

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.

UPDATED 12.18.2024): Article revised to include the NEW CPT/HCPCS codes.

UT Health (Internal Use Only) 2025 Resource Chart Links

Advanced Primary Care Management

Behavioral Health Caregiver Training

Behavioral Health Interprofessional Consultation service via telephone, internet, or EMR

Caregiver Training

Telemedicine and Non-Face-to-Face Services