What is her actual specialty? And what is the specialty of the provider(s) who are sending patients to her for OMT? If the same specialty (i.e. Family Practice), and the same group, the patients are established. If a different specialty, they can be considered new patients as long as she or someone of the same specialty in the group have not seen them in three years. Also, be sure any E/M is truly a significant, separately identifiable service from the OMT.
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