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If a patient presents to ER and needs urgent Heart Cath after the procedure the provider dictates H&P and/or Consult can you bill E/M code after the procedure was done using Modifier 25?
These are the tough questions that basically come down to the documentation on medical records. To be able to use modifier 25 the services between the E&M and the procedure must be significant and separately identifiable. So basically the E&M would need to be above and beyond the evaluation or management that would normally be required for the pre/post and procedure administered.
Based on previous history, in an ER Department situation there is often a justifiable reason for both, but again it all comes down to how the information is documented.