Everything I have seen and heard over the years states it is just as bad as upcoding. However, we do have an EMR and there are times when our physician should downcode based upon medical decision making. It's very easy to push an established visit to a level 4 or 5 by providing a detailed/comprehensive history and physical, and some physicians prefer to document to that level at every visit. However, many of our payers require medical decision be one of the two components used to determine the E&M level.
That being said, we do have cases where our system would code out a level 4, but the medical decision making falls into the low category and the visit is ultimately billed as a 3.