E/M Services

In 2019, the OIG performed an audit of claims that were billed by podiatrists for E/M services. The audit examined whether podiatrists’ claims for E/M services billed with the 25 modifier, which indicates that the E/M service was significant and separately identifiable from a minor surgical procedure billed on the same date of service, one that has a postoperative global period of 0 or 10 days, complied with Medicare’s guidelines. One hundred (100) claims were sampled, and it was found that forty-four (44) claims did not comply with Medicare’s guidelines. The OIG estimated that $39.6 million of the $222.5 million paid by Medicare during the audit period was inappropriate. It was found that during the audit period, CMS’s oversight may not have been sufficient to prevent improper payments.

“We have a disagreement among our group regarding radiology billing. If a new patient presents with x-rays, MRI, etc., from an outside source, without a report (or with an inadequate report), can the podiatrist bill for the professional component of reading the imaging studies provided?”