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Yes, I agree with the -25 modifier. What you may be thinking about is the fact that add-on codes cannot carry a -51 modifier but they can be modified with other HCPCS Level I or II modifiers.
Just an FYI per ACEP for billing facility ED charges:
CPT 99292 As above in additional 30 minute increments. Record the TOTAL critical care time. The first 30-74 minutes equal code 99291. If used, additional 30 minute increments (beyond the first 74 minutes) are coded 99292. Medicare does not pay for code 99292 because it is considered packaged into 99291; however the services should be reported as appropriate.