You must choose to use either the 95 or 97 guidelines (no mixing in the same encounter) You can choose which ever guidelines give you the best reimbursement on a case by case basis. There is a reference to this in the section of your CPT where the E/M section starts. (If you have AAPC's 2008 book, that is page 4 of E/M under the 1995 Federal Guideance heading).
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