In reading the Guidelines on page 369 of the professional version of CPT I can understand where the carrier would interpret the guidelines as needing a modifier 25 for the E&M service provided the same day. I run into carriers telling me how to use, or what modifiers to use on a regular basis. I have even tried to tell them that the modifier is not necessary per coding edits. If you carrier is telling you to append the modifier to get paid properly then be sure you append the -25 modifier. Understanding guidelines can be easy at times, understanding the carrier's understanding of the guidelines can make us a bit crazy.
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