Wiki Care Plan and E/M

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I code for some Chiropractors that do not adjust until the patient's second visit. At the second visit, the Dr. will discuss their findings from the XRay, and create a Care Plan- Educating the patient on how often they need to be seen and what exercises they can do to speed up the process. They also spend a fair amount of time discussing the billing aspect- How much they predict insurance will pay, and what will be out of pocket.
They then perform the first adjustment. The appointment typically lasts 30-45 min- only about 10 of which are spent as the adjustment.

I told the Chiropractors that I believe that they can bill a low level E/M with -25 modifier in addition to the adj. code. They would like additional documentation backing this up.

Does anyone have any opinions or information that I could present to the doctors?