It depends on the circumstances. Was the procedure planned or was it done urgently or at the request of another doctor? If it wasn't planned, a follow up may be warranted. I'm assuming the procedure done had a 0-day global. Since your doc is billing mid-level follow up code, I'm assuming the patient is fairly sick and the follow up visits are billable (if the documentation supports it). In the practice where I work, if the procedure is minor but the patient was kept overnight with no complications, a follow up visit is not charged.
I hope this helps...
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