A simple biopsy has 0 postop days for a reason. It usually doesn't require postoperative visits for wound checks because it's usually just bandaged or ster-stripped and left to heal with the patient being given easy-to-follow postop care instructions. Punch biopsies or shave biopsies are minimally invasive and simple postopcare is enough to promote healing without infection.
Most practices call or write with biopsy results. If further action is warranted, a separate visit can be scheduled over the phone for the removal, or the patient can come in to discuss the results and get further treatment, especially in the case of cancerous type lesions.
That being said, since the biopsy codes have 0 postop days and if a patient IS brought in to discuss results or deal with any wound care issues, you can most certainly charge an E/M visit. It would be a lower level of care, or sometimes even just a nurse visit 99211.
However if it's your practice's norm to have EVERY patient come in for an E/M visit to discuss results and check wounds, you may raise some red flags in the future for unnecessarily trying to increase revenue by scheduling unnecessary visists, especially when it's the norm NOT to.
And in all practicality, it's unfair to the patient. A second visit from their busy days and additional copays or deductibles to be met when it can be handled over the phone.