I would ask first, who is telling you this?
In my experience, procedures and E/M charges are considered separately, so whether it is first or last on the claim really does not matter. I have seen situations where the E/M was billed on a completely different claim, and on the same claim, in every number of positions like first, middle, last- really I have never seen a difference.
As far as documentation, I don't know of any- this is just my own experience. How about asking this person to show YOU documentation stating to always bill the E/M code first. I have never heard of that officially- it sounds like it may be this person's personal preference.
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