99417 vs G2212: Prolonged Services Codes

There are two prolonged outpatient E/M codes describing nearly the same service, and they become reportable at different numbers of minutes. That is not an accident or a transitional artifact. CMS created the second one deliberately, in 2021, because it disagreed with how CPT had defined the first — and the disagreement has never been resolved.

If you bill both Medicare and commercial payers, you have to run both rules.

First, a note on which G-code is current

Prolonged services coding has been renumbered enough times that stale code numbers circulate widely. So, verified against the CMS HCPCS Level II alpha-numeric file (July 2026 and October 2026 releases):

G2212 is the current Medicare code for prolonged office or other outpatient E/M services. It is active in both the July 2026 and October 2026 files, with no termination date, and its descriptor is unchanged. It has been the Medicare O/O prolonged code continuously since 2021.
G0316, G0317 and G0318 are the Medicare prolonged codes for the other E/M families, effective January 1, 2023.
There is no HCPCS code G2318. It does not appear in the July 2026 or October 2026 HCPCS files. If you have seen it referenced, it is an error.

With that settled, the substantive question is 99417 versus G2212.

The two descriptors

CPT 99417 is the AMA’s prolonged outpatient E/M add-on, reported in 15-minute increments alongside the highest-level office/outpatient visit codes.

HCPCS G2212, as it reads in the current CMS HCPCS file:

Prolonged office or other outpatient evaluation and management service(s) beyond the maximum required time of the primary procedure which has been selected using total time on the date of the primary service; each additional 15 minutes by the physician or qualified healthcare professional, with or without direct patient contact (list separately in addition to cpt codes 99205, 99215, 99483 for office or other outpatient evaluation and management services). (Do not report g2212 on the same date of service as 99358, 99359, 99415, 99416). (Do not report g2212 for any time unit less than 15 minutes)

Note the word maximum. That single word is the entire dispute.

Why CMS built a parallel code

The reasoning is set out at length in the CY 2021 PFS final rule (85 FR 84572–84574), and it is worth understanding because it explains why the two thresholds can never be reconciled by a coder.

When the office/outpatient E/M codes were revised for 2021, they stopped having a single “typical time” and acquired time ranges. CPT 99215 became 40–54 minutes; 99205 became 60–74 minutes.

CPT’s prolonged code, 99417, was written to begin “beyond the minimum required time of the primary procedure.” CMS quoted the CPT 2021 Professional Edition descriptor directly in the rule to make the point.

CMS objected that this double-counts time. Its worked example is the clearest statement of the problem:

“As a specific example, the time range for CPT code 99215 is 40-54 minutes. If the reporting practitioner spent 55 minutes of time, 14 of those minutes are included in the services described by CPT code 99215. Therefore, only 1 minute should be counted towards the additional 15 minutes needed to report CPT code 99417.”

In other words: if 99215 is already paying for up to 54 minutes, then minutes 41 through 54 have already been purchased. Allowing a 15-minute prolonged unit to start at minute 41 bills the same time twice.

CMS also complained that the CPT descriptor’s terms were unclear — “the term ‘total time’ is unclear because office/outpatient E/M visits now represent a range of time, and ‘total’ time could be interpreted as including prolonged time. Further, the term ‘usual service’ is undefined.”

Commenters pushed back, some arguing “the CPT Editorial Panel intended to apply the general CPT rule where practitioners can report a timed code once the midpoint is reached.” CMS was unpersuaded: “It has not been our understanding that CPT intended for the midpoint time to suffice for reporting this code, and regardless, we did not previously finalize or intend to apply such a policy.”

So CMS finalized its own rule — prolonged time starts after the maximum — and, rather than apply a Medicare-specific interpretation to a CPT code, created G2212 “to be used when billing Medicare for this service instead of CPT code 99417, starting in 2021.”

One detail that matters commercially: CMS stated that “the valuation for HCPCS code G2212 will be the same as for CPT code 99417.” The codes are worth the same. They simply become reportable at different times.

The practical difference

Applying each rule to the level 5 codes:

Base code	CPT time range	CPT 99417 becomes reportable	Medicare G2212 becomes reportable
99205 (new patient)	60–74 minutes	75 minutes	89 minutes
99215 (established patient)	40–54 minutes	55 minutes	69 minutes

The Medicare thresholds of 89 and 69 minutes are confirmed in CMS’s current MLN booklet on Evaluation and Management Services (MLN006764, May 2026), which sets out the full reporting table. The CPT figures follow arithmetically from the “minimum required time” language CMS quoted.

The gap is 14 minutes for both codes — exactly the width of the level 5 time range minus one minute, which is precisely the quantity CMS said was being double-counted.

A 76-minute new patient visit is therefore a billable prolonged service under CPT rules and not under Medicare rules. That is the single most consequential fact on this page.

The whole Medicare prolonged E/M family

CMS extended the same approach to the remaining E/M families in the CY 2023 PFS final rule, creating three more Medicare-specific codes effective January 1, 2023:

G2212 — prolonged office or other outpatient E/M. Base codes 99205, 99215, and 99483 (cognitive assessment and care planning, added in CY 2023).
G0316 — prolonged hospital inpatient or observation care. Base codes 99223, 99233, 99236.
G0317 — prolonged nursing facility services. Base codes 99306, 99310.
G0318 — prolonged home or residence services. Base codes 99345, 99350.

CMS finalized G0316, G0317 and G0318 with a work RVU of 0.61 each, and direct practice expense inputs “identical to the RUC-recommended PE inputs for CPT code 99417.”

Prolonged services are not reportable at all with emergency department visits — CMS’s stated reason being that ED codes are not selected on time — nor with discharge day management, consultations or critical care.

What happened to the older CPT prolonged codes

Several codes that appear in older guidance are gone or unusable for Medicare:

99354–99357 (prolonged services with direct patient contact, other than office/outpatient) were deleted by the CPT Editorial Panel effective 2023.
99358 and 99359 (prolonged services on a date other than the visit) still exist in CPT, but CMS assigned them status indicator “I” — not valid for Medicare purposes, Medicare uses another code. They cannot be billed to Medicare.
99418 is CPT’s prolonged code for the inpatient and other E/M families. Medicare uses G0316, G0317 and G0318 instead.
99415 and 99416 describe prolonged clinical staff time, which is a different service. G2212 must not be reported on the same date of service as 99358, 99359, 99415 or 99416.

CMS’s reasoning for rejecting the date-shifted codes is worth noting for anyone arguing the point: “We do not believe the solution lies in open-ended codes like CPT codes 99358-9, which have no beginning, end, or specified setting, seemingly could be used when a visit is not timed, and cannot readily be associated or connected with a particular face-to-face visit.”

Which code to send to which payer

Traditional Medicare Part B: G2212, at the Medicare thresholds. 99417 is not the Medicare code.
Medicare Advantage: follows plan rules. Many mirror Fee-for-Service policy; confirm rather than assume.
Commercial payers: generally CPT 99417, but this is payer-specific. Some commercial plans have adopted the Medicare G codes and Medicare thresholds. Verify in writing.
Medicaid: varies by state programme.

The operational consequence is that a practice cannot run one time threshold across its whole book of business. The visit that qualifies for one payer at 76 minutes does not qualify for another until 89.

Both AMA and CMS have acknowledged the problem. In the CY 2023 rulemaking the AMA “urged CMS to work with the CPT/RUC E/M Workgroup to bring CMS and CPT prolonged services policies into alignment,” and CMS responded that it “agree[s] with commenters that a uniform code set for use by all payers for prolonged services is preferable” and would “continue to work with the AMA to consider further refinements and standardization of this code set through notice and comment rulemaking.” As of the CY 2026 final rule and the October 2026 HCPCS file, no such alignment has been finalized.

Frequently asked questions

Is 99417 or G2212 the right code for Medicare?

G2212. CMS created it expressly “to be used when billing Medicare for this service instead of CPT code 99417.”

Did G2212 replace an older code, or get replaced?

Neither. G2212 was created in the CY 2021 PFS final rule and remains active and unchanged in the current CMS HCPCS file. What it replaced, for Medicare purposes, was CPT 99417.

What is G2318?

Not a HCPCS code. It does not appear in the CMS HCPCS Level II alpha-numeric file for July 2026 or October 2026. The Medicare prolonged E/M codes are G2212, G0316, G0317 and G0318 — the last of which is likely the source of the confusion.

Do 99417 and G2212 pay the same?

CMS set them at the same value: “The valuation for HCPCS code G2212 will be the same as for CPT code 99417.” The practical difference is when each becomes reportable, not what it is worth per unit.

Can I report G2212 with a level 4 visit?

No. G2212 lists separately in addition to CPT 99205, 99215 and 99483 only. Prolonged services attach to the highest-level code in the family, because a visit that has not reached level 5 has not yet exhausted the base code’s time.

Can G2212 be reported when the visit level was selected on medical decision making?

No. Prolonged services under both the CPT and Medicare rules require that the visit level was selected using time. CMS’s booklet notes the requirement explicitly: “You must use time to select your visit level.”

How many units of G2212 can be reported?

Each additional completed 15 minutes is one unit, and CMS’s own table runs to three or more units. But the code must never be reported “for any time unit less than 15 minutes.” The exact thresholds are set out in our guide to prolonged services time thresholds.