We may be touching on two different scenarios. In one, the patient has already been seen (recently) and they decided on a visco injection series, injections are scheduled and that is the sole purpose the patient returns.
In the second (which I think is what you are talking about) is an established patient comes in with worsening OA/pain. The provider re-evaluates and decides on either visco or maybe cortisone to be given or started at that visit. In this case it may be entirely appropriate to code the E/M & the 25. That's why initially I said it depends on the documentation. Each of these would have to be taken on a case by case basis. In many cases patients are managed with OA for years before they finally end up with a TKA or THA or TSA depending on the joint.
Maybe a patient had come in last year or 6 months ago, has been managing with OTC meds but now it's getting worse and it's time for injections. It would make sense to see an E/M and injection at this point because it has been so long since the patient was last seen. There could be health status or other changes that have to be considered, they may need new Xrays. On the other hand, maybe the provider saw the patient a week or two ago, they tried OTC but also talked about injections, it still hurts, they come back in and get an injection. Has anything changed, was the note exactly the same except now says, yup let's give you an injection (like we talked about a couple weeks ago)?
There is no 100% yes or no, it depends on the encounter. However, if it is for a #2 or #3 in a Visco series, it's more than likely a hard no (unless something else is wrong and evaluated/managed). I know people always want a black and white answer but it's not possible
Some of these may help:
I don't have any notes. If you can print one out just take a pencil and cross out anything related to the H&P (pre-service), actual administration of the injection (intra-service), and post procedure result/directions (post-service). That is all work that is counted toward the 20610/20611.