Most payers, including Medicare, have policies that will only allow payment for two E/M services by the same provider on the same day when the patient returns and is seen for a completely unrelated problem at the second visit. Getting payment in this situation will require an appeal with records that show that this was the case, and even then, I’ve heard that it can be difficult to get the denial reversed. But if the two visits aren’t for unrelated problems, you will most probably need to code from the combined notes and submit a single E/M to represent both.