We too are looking into this and I'm so glad the modifier 56 was mentioned. I was trying to find some guidance in how it should be reported, as CMS IOM only provides direction for use of the 54/55 modifiers. Sounds like it should be applied to the surgical procedure code, is that correct? We have NPP's providing the required pre-op anesthesia clearance for dental surgeons, since I'm told it is not w/in their (dentists) scope of practice to provide the h&p. I agree that the NPP's should not being billing an E/M visit for this (consult or outpt visit), since a preop h&p is considered part of the global payment.
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