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This month’s selection:

I was wondering if you could provide me some coding/documenting requirements for CPT codes 95251 and 95249 with information on incident to billing also?

Jessica Fiorelli RHIT, CCS, CCS-P
Coding/Billing Team Lead
Columbus Family Practice

Response:

CPT codes 95249 and 95251 continue to generate coding and documentation questions as continuous glucose monitoring (CGM) utilization expands across outpatient and physician practice settings.

CPT 95249 is reported for personal CGM startup and training when the patient owns or provides the equipment. Documentation should support patient training; sensor placement and hookup, when applicable; initiation of data collection; and appropriate device education. Best practice documentation elements may include the following:

• device type;
• patient consent and/or documented understanding of device use;
• training and education provided;
• date of CGM initiation;
• sensor placement and hookup, when applicable;
• confirmation that the patient will use the device for the required monitoring period;
• documentation of patient participation and compliance instructions; and
• any technical issues, calibration requirements, or troubleshooting addressed during training.

CPT 95251 represents the professional analysis, interpretation, and report of CGM data. Documentation should support a minimum of 72 hours of data collection, provider review and interpretation of glucose patterns and variability, assessment of hypoglycemia and hyperglycemia trends, and any resulting clinical recommendations or treatment adjustments. Importantly, CPT 95251 should not be billed solely for data download without documented provider analysis and interpretation.

From a documentation perspective, the interpretation/report should clearly demonstrate medical necessity and clinical decision-making. Best practice documentation elements may include the following:

• dates or duration of CGM data reviewed;
• time in range and percentage of hyperglycemic/hypoglycemic readings;
• glycemic variability and glucose management indicator, when available;
• identification of clinically significant trends or excursions;
• correlation of glucose findings with medications, meals, activity, or symptoms, when applicable;
• provider assessment and interpretation of findings;
• resulting treatment recommendations, medication adjustments, education, or follow-up plan; and
• provider authentication/signature.

If a separately identifiable evaluation and management (E/M) service is performed on the same date as CGM services, modifier 25 may be appended to the E/M code when supported by documentation. The E/M service should reflect work above and beyond the CGM interpretation and reporting service alone.

Coders should also distinguish between CMS coverage guidance for CGM equipment and supplies vs professional reimbursement for CGM-related services. CMS Article A52464 (Glucose Monitor Policy Article) primarily addresses DMEPOS coverage criteria for CGM devices and supplies, while professional reimbursement for CPT codes 95249, 95250, and 95251 is recognized separately through the Medicare Physician Fee Schedule (MPFS).

CMS recognizes CPT 95251 within the MPFS as a professional interpretation and reporting service furnished in physician office and outpatient settings. In CY 2025 MPFS Final Rule commentary related to telehealth policy, CMS further noted that CPT 95251 is “not inherently face-to-face,” since the patient does not need to be present for the interpretation service to occur.

Incident-to considerations may apply to certain technical components of CGM services performed by auxiliary clinical staff under appropriate supervision requirements. However, the interpretation and report associated with CPT 95251 should be performed and documented by the billing physician or qualified health care professional.

Key differences in documentation and incident-to considerations between CPT 95249 and CPT 95251 are important from both a coding and compliance perspective.

For CPT 95249, documentation is primarily focused on the technical initiation and patient training components of personal CGM use. Services such as patient education, device setup, sensor placement and hookup, calibration when applicable, and initiation of monitoring may be performed by clinical staff under appropriate supervision requirements and consistent with payer policy and state scope-of-practice rules. Documentation should clearly support the training and startup activities performed.

By contrast, CPT 95251 represents the professional analysis, interpretation, and report of CGM data. Documentation requirements for 95251 are more clinically focused and should demonstrate provider interpretation, assessment of glucose trends and variability, and resulting clinical recommendations or treatment decisions. Importantly, CPT 95251 should not be reported for data download alone or for purely technical review without documented provider analysis.

From an incident-to perspective, coders should distinguish between technical support activities and the professional interpretation component. While auxiliary clinical staff may assist with certain technical aspects of CGM services under applicable supervision requirements, the interpretation and report associated with CPT 95251 should be personally performed, documented, and authenticated by the billing physician or qualified health care professional.

Additional industry guidance from the American Diabetes Association and the American Academy of Family Physicians reinforces these documentation and reporting expectations, including the minimum 72-hour data requirement, interpretation/report documentation elements, modifier 25 considerations, and provider supervision requirements for CGM-related services.

Relevant references include the following:

• CMS Physician Fee Schedule Overview: https://www.cms.gov/medicare/payment/fee-schedules/physician

• CMS Physician Fee Schedule Lookup Tool: https://www.cms.gov/medicare/physician-fee-schedule/search

• CMS Incident-To Services Guidance: https://www.cms.gov/medicare/payment/fee-schedules/physician-fee-schedule/advanced-practice-non-physician-practitioners/incident-services-supplies

• CMS Glucose Monitor Policy Article (A52464): https://www.cms.gov/medicare-coverage-database/view/article.aspx?articleId=52464

• American Diabetes Association – Frequently Used Billing Codes for Diabetes Technology: https://diabetes.org/sites/default/files/2025-11/FrequentlyUsedBillingCodes_FINAL.pdf

• American Academy of Family Physicians – Coding for Remote Patient Monitoring and Continuous Glucose Monitoring: https://www.aafp.org/practice-operations/billing-and-coding/remote-patient-monitoring-continuous-glucose-monitoring

— Maya Turner, CPC, CPB, CPMA, CPCO, CFPC, CPC-I, is director of education and co-owner of MEdUTrain, and owner and managing director of Turner Expert Consulting Services, LLC. She has 30 years of experience working in health care and coding compliance, which includes evaluation and management and nonprocedural auditing, physician education, and designing course curriculums for the latest trends for inpatient and professional revenue cycles.