Health Care DEPARTMENT OF HEALTH & HUMAN SERVICES Financing Administration REFER TO: FQA-541 Memorandum Date AUG 27 1993 From Director, Bureau of Policy Development Director, Bureau of Program operations Subiect Extra documentation Requirements with Modifier 25 Services To All Associate Regional Administrators for Medicare We have been advised that some carriers--e.g., Pennsylvania, Massachusetts, Maryland, and Nevada--are routinely imposing additional documentation requirements prior to paying for modifier 25 services. You will recall that modifier 25 is to be used by physicianS when they are billing for an evaluation and management service provided on the same day that they provided a minor surgical service to the same patient. prior to billing modifier 25, the physician is to have determined that the evaluation and management service for which he or she is billing is a service which is clearly distinct from the surgical service. Once the physician makes the determination to bill modifier 25 with an evaluation and management service, that service is to be paid for. Except as noted below, no other carrier screens or documentation requirements are to be imposed. The exceptions are that prepayment documentation is or may be required with modifier 25: o when inpatient dialysis services are billed (see the attached June 12, 1992 memorandum from Charles Booth to all ARAs for Medicare), o when pre-operative critical care codes are being billed for within a global surgical period (see issue 43 in the May 29, 1992 carrier Medical Directors' report--which describes required documentation that the critical care services be unrelated to the surgery), or o when a carrier has conducted a specific medical review process and determined, after reviewing the data, that an individual or a group has high statistics in terms of the use of modifier 25, has done a case-by-case review of the records to verify that the use of modifier was inappropriate and has educated the individual or group. 2109 *********************************************************************** DEPARTMENT OF HEALTH & HUMAN SERVICES Financing Administration -------------------------------------------------------------------------------------------------------------------- MEMORANDUM FQA - 541 Date JUN 23 1992 From Director Burueau of Policy Development Subject Payment for Evaluation end Management Services on the same Day as A Procedural Service All Associate Regional Administrators To for Medicare An you know, we have a policy which does not permit payment for evaluation and management services performed on the same day as a minor procedural service, unless the evaluation and management service is a "documented, separately identifiable service." It has come to our attention that some carriers are not paying for such separately identifiable services unless they are. "unre1ated" to the procodural service. This is not correct. A docunented, separately identifiable related service is to be paid for. We would define related as being caused or prompted by tbe same symptoms or conditions. Kathleen A. Buto cc: Gary Kavanagh, BPO Jean Harris, OFO, BPO Office of Field Operations Office of Issuances Cindy Reed. OFP. BPO 2113