Medicare allows an Annual Wellness Visit and a medically necessary, separately identifiable evaluation and management service to be reported on the same date when all requirements are met. In this situation, annual wellness visit Modifier 25 rules require the modifier to be appended to the additional E/M code—not to G0438 or G0439.
For example, a practice may report G0439 with 99214-25 when the provider completes the subsequent Annual Wellness Visit and performs significant additional work to evaluate or manage a medical problem. The documentation must clearly distinguish the problem-oriented service from the routine wellness components.
This guide explains how to bill 99214 with G0438 or G0439, where to place Modifier 25, what documentation is needed, and how to prevent common Medicare billing denials.
Understanding annual wellness visit Modifier 25 requirements helps practices report separate E/M work accurately.
Important: Modifier 25 does not automatically justify separate reimbursement. The additional E/M service must be medically necessary, significant, separately identifiable, and supported by the medical record. Commercial Medicare Advantage plans may apply additional requirements.
What Is an Annual Wellness Visit?
The Medicare Annual Wellness Visit is a preventive service designed to develop or update a personalized prevention plan. It is not the same as a comprehensive annual physical examination.
Medicare uses two primary HCPCS codes for Annual Wellness Visits:
- G0438: Initial Annual Wellness Visit, available once after the beneficiary meets Medicare eligibility and timing requirements.
- G0439: Subsequent Annual Wellness Visit, generally available once every 12 months after the previous eligible wellness visit.
Before selecting a code, practices should verify the patient’s Medicare eligibility and wellness-visit history. Review our Annual Wellness Visit CPT codes guide for additional information about G0402, G0438, and G0439.
What Is Modifier 25?
Modifier 25 indicates that a significant, separately identifiable evaluation and management service was performed by the same physician or qualified healthcare professional on the same day as another procedure or service.
During an Annual Wellness Visit, a patient may present with a new complaint, worsening chronic condition, medication-related concern, or another problem requiring additional assessment and management. If the provider performs medically necessary work beyond the requirements of the wellness visit, an appropriate office or outpatient E/M code may be reported with Modifier 25.
The modifier communicates that the additional E/M service should not automatically be bundled into the wellness visit.
Where Does Modifier 25 Go?
For annual wellness visit Modifier 25 billing, append the modifier to the separately reported E/M code.
Correct examples include:
- G0438 + 99213-25
- G0438 + 99214-25
- G0439 + 99213-25
- G0439 + 99214-25
Do not append Modifier 25 to G0438 or G0439 when it is being used to identify the separate problem-oriented E/M service.
The correct placement is:
G0439 + 99214-25
Not:
G0439-25 + 99214
This distinction is important because Modifier 25 describes the separate E/M work, not the Annual Wellness Visit itself.
Can You Bill 99214 With G0439?
Yes, 99214 and G0439 may be reported together when the provider performs a subsequent Annual Wellness Visit and a significant, separately identifiable, medically necessary level-four established-patient E/M service.
The claim may include:
- G0439 for the subsequent Annual Wellness Visit
- 99214-25 for the separate problem-oriented E/M service
However, the presence of a chronic condition alone does not automatically support 99214. The provider must perform and document additional work that satisfies the requirements for the selected E/M level.
The documentation supporting 99214 should be based only on the work performed for the problem-oriented service. Time and activities already counted toward G0439 should not be counted again toward the E/M service.
Can You Bill 99214 With G0438?
Yes, 99214 may also be billed with G0438 when the initial Annual Wellness Visit and a qualifying separate E/M service occur during the same encounter.
An appropriate claim may report:
- G0438 for the initial Annual Wellness Visit
- 99214-25 for the separately identifiable E/M service
The medical record should clearly demonstrate that the problem required evaluation or management beyond the components normally included in G0438.
Practices should also verify that the patient is eligible for an initial Annual Wellness Visit. G0438 is generally reported only once for a Medicare beneficiary and is subject to Medicare timing requirements.
When Is a Separate E/M Service Appropriate?
A separate E/M service may be appropriate when a medical problem requires meaningful additional work beyond the preventive planning included in the Annual Wellness Visit.
Examples may include:
- Evaluating a new symptom or complaint
- Assessing a worsening chronic condition
- Adjusting medication based on the patient’s condition
- Reviewing abnormal findings that require additional management
- Ordering diagnostic testing for a separately evaluated problem
- Developing or changing a treatment plan
- Addressing an acute illness identified during the encounter
A brief mention of a stable diagnosis, routine medication-list confirmation, or work already required for the Annual Wellness Visit may not support separate E/M billing.
The question is not simply whether a diagnosis was documented. The record must show whether the provider performed significant and separately identifiable evaluation or management work.
Example of G0439 With 99214-25
A Medicare patient arrives for a scheduled subsequent Annual Wellness Visit. The provider completes the required wellness elements, updates the health-risk assessment, reviews preventive recommendations, and develops the prevention plan.
During the encounter, the patient also reports worsening shortness of breath. The provider performs a separate problem-focused evaluation, reviews relevant clinical information, evaluates possible causes, orders diagnostic testing, and creates a treatment and follow-up plan.
If the additional work independently supports 99214, the practice may report:
- G0439
- 99214-25
The record should separate the wellness components from the assessment and management of the patient’s shortness of breath.
Example That May Not Support 99214-25
A patient attends a subsequent Annual Wellness Visit. The provider reviews the patient’s existing conditions and medication list as part of the wellness assessment. No new problems are evaluated, no treatment is changed, and no significant additional medical decision-making occurs.
In this case, reporting 99214-25 merely because chronic diagnoses appear in the record may not be supported.
Modifier 25 should reflect documented additional work—not the routine review already included in the Annual Wellness Visit.
Documentation Requirements for Modifier 25
Strong documentation is essential when reporting an E/M service with G0438 or G0439. The note should allow a reviewer to distinguish the wellness service from the separate medical evaluation.
Annual wellness visit Modifier 25 documentation should clearly separate preventive components from problem-oriented medical decision-making.
Document the following when applicable:
Annual Wellness Visit Components
Record the required elements of the initial or subsequent Annual Wellness Visit, including the health-risk assessment, medical and family history updates, required screenings, risk-factor review, and personalized prevention plan.
Use our Annual Wellness Visit documentation checklist to review the principal documentation elements.
Separate Medical Problem
Identify the new, worsening, or actively managed condition that required additional evaluation or treatment.
Additional Clinical Work
Document the separate history, medically appropriate examination, assessment, medical decision-making, orders, treatment changes, and follow-up plan related to the problem-oriented service.
E/M Level Support
Select the E/M code using the applicable medical decision-making or time requirements. Do not include time already attributed to the Annual Wellness Visit when selecting a time-based E/M level.
Clear Separation Within the Note
The services do not necessarily require two completely separate notes, but the documentation should make the distinct work easy to identify. Separate headings or sections can improve clarity.
Annual Wellness Visit Modifier 25 Billing Checklist
Before submitting G0438 or G0439 with an E/M service, confirm that:
- The patient is eligible for the reported Annual Wellness Visit
- All required AWV components are documented
- A separate medical problem required additional work
- The additional service was medically necessary
- The documentation supports the selected E/M level
- Modifier 25 is attached to the E/M code
- Wellness activities were not counted again toward the E/M level
- Diagnosis codes accurately support each reported service
- The payer’s current billing policies were reviewed
- The patient was informed that cost-sharing may apply to the additional E/M service
A consistent pre-submission review can reduce avoidable coding errors and improve claim accuracy.
Common Billing Errors to Avoid
Placing Modifier 25 on G0438 or G0439
Modifier 25 belongs on the separately identifiable E/M code, such as 99214-25.
Billing an E/M Code for Routine AWV Work
Services already included in the wellness visit should not be used to justify a second E/M service.
Selecting 99214 Without Sufficient Support
Not every separate problem supports 99214. The documentation must satisfy the requirements for the level reported.
Using the Same Work Twice
Do not count the same history, decision-making, counseling, or time toward both the wellness visit and the additional E/M service.
Failing to Verify Eligibility
Submitting G0438 or G0439 without checking the patient’s wellness-visit history can result in a denial.
Ignoring Medicare Advantage Policies
Medicare Advantage plans must cover Medicare benefits, but claim-processing procedures and documentation requests may vary. Verify the plan’s current requirements.
Failing to Explain Patient Cost-Sharing
The Annual Wellness Visit may have no Medicare cost-sharing when requirements are met, but the separately reported E/M service may create a deductible or coinsurance responsibility.
Does Modifier 25 Guarantee Payment?
No. Annual wellness visit Modifier 25 reporting does not guarantee reimbursement.
A payer may deny the additional E/M service because of:
- Insufficient documentation
- Incorrect modifier placement
- Failure to support the E/M level
- Eligibility or frequency limitations
- Diagnosis and procedure inconsistencies
- Payer-specific claim edits
- Medical-necessity concerns
- Duplicate or overlapping services
When a claim is denied, review the remittance advice, claim-adjustment reason code, remark code, medical record, and applicable payer policy before correcting or appealing it.
Can G2211 Be Billed With an AWV and 99214-25?
Beginning January 1, 2025, Medicare permits G2211 to be paid with an office or outpatient E/M service reported with Modifier 25 when an eligible Part B preventive service—such as an Annual Wellness Visit—is also provided on the same date.
A possible code combination may be:
- G0439
- 99214-25
- G2211
However, G2211 has its own requirements. It should be reported only when the longitudinal or ongoing-care relationship described by Medicare is supported. Its availability with an Annual Wellness Visit does not eliminate the documentation requirements for 99214, Modifier 25, or G2211.
Review the current CMS Annual Wellness Visit guidance and payer instructions before claim submission.
How Practices Can Reduce AWV Billing Denials
Practices can improve their Annual Wellness Visit workflow by:
- Verifying AWV eligibility before the appointment
- Using separate documentation sections for wellness and problem-oriented work
- Training providers on the difference between an AWV and a routine physical
- Applying Modifier 25 only when the additional E/M requirements are met
- Reviewing documentation before submitting higher-level E/M codes
- Monitoring denials by code, payer, provider, and reason
- Updating billing workflows when Medicare or payer policies change
The goal is not to add an E/M code to every Annual Wellness Visit. The goal is to accurately report both services when the clinical work and documentation support them.
A consistent annual wellness visit Modifier 25 workflow can help prevent unsupported coding and avoidable claim denials.
Frequently Asked Questions
Can you bill 99214 with G0439?
Yes. A practice may bill 99214 with G0439 when the provider performs a significant, separately identifiable, medically necessary E/M service in addition to the subsequent Annual Wellness Visit. Append Modifier 25 to 99214 and ensure the documentation independently supports the E/M level.
Can you bill 99214 with G0438?
Yes. G0438 and 99214-25 may be reported together when the initial Annual Wellness Visit and a qualifying separate problem-oriented E/M service are completed on the same date.
Does Modifier 25 go on G0439 or 99214?
Modifier 25 goes on the separately reported E/M code. The correct combination is generally G0439 and 99214-25, not G0439-25 and 99214.
Does every chronic condition justify 99214-25?
No. Listing or briefly reviewing a chronic condition does not automatically support a separate E/M service. The record must demonstrate significant additional evaluation or management and satisfy the requirements for 99214.
Will the patient owe a copay for 99214-25?
The Annual Wellness Visit may have no Medicare cost-sharing when coverage requirements are met. The separately billed E/M service may be subject to the patient’s deductible or coinsurance.
Can G2211 be billed with G0439 and 99214-25?
Medicare may allow G2211 with an eligible office or outpatient E/M service reported with Modifier 25 when an Annual Wellness Visit is performed on the same date. Every code must meet its individual requirements, and payer policies should be verified.
Get Help With Annual Wellness Visit Billing
Correctly reporting an Annual Wellness Visit and a separate E/M service requires accurate eligibility verification, documentation review, code selection, modifier placement, and denial follow-up.
The Ashez Group provides medical billing and coding support for primary care practices seeking cleaner claims and stronger revenue-cycle workflows. Our team can help review Annual Wellness Visit billing procedures, identify recurring denial patterns, and support compliant claim submission.
Contact The Ashez Group to discuss your medical billing, coding, or denial-management needs.
Disclaimer: This article is for general educational purposes and does not constitute legal, medical, or coding advice. Coding and coverage requirements may change and can vary by payer, plan, contract, and documented circumstances. Verify current CMS and payer guidance before submitting claims.
