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Dermatology Providers Generally Met Medicare Requirements for Evaluation and Management Services

Announced on  | Last Modified on  | Project Number: A-04-21-04083

OBJECTIVE

Medicare covers an Evaluation and Management (E/M) service when the service is reasonable and necessary for the diagnosis or treatment of illness or injury, or to improve the functioning of a malformed body member. Generally, Medicare payments for global surgery procedures include payments for necessary preoperative and postoperative services related to surgery when furnished by a surgeon. Medicare global surgery rules define the rules for reporting E/M services with minor surgery and other procedures covered by these rules. In general, E/M services provided on the same day of service as a minor surgical procedure are included in the payment for the procedure. The decision to perform a minor surgical procedure is included in the payment for a minor surgical procedure and must not be reported separately as an E/M service. An E/M service should be billed only on the same day if a surgeon performs a significant and separately identifiable E/M service that is unrelated to the decision to perform a minor surgical procedure. In this instance, the provider should append a modifier 25 to the appropriate E/M code. In 2019, about 56 percent of dermatologists' claims with an E/M service also included minor surgical procedures (such as lesion removals, destructions, and biopsies) on the same day. This may indicate abuse whereby the provider used modifier 25 to bill Medicare for a significant and separately identifiable E/M service when only a minor surgical procedure and related preoperative and postoperative services are supported by the beneficiary's medical record. We will determine whether dermatologists' claims for E/M services on the same day of service as a minor surgical procedure complied with Medicare requirements.

TIMELINE

  • March 22, 2021
    Announced
  • November 18, 2025
    Complete

    Dermatology Providers Generally Met Medicare Requirements for Evaluation and Management Services has been marked as complete. This audit resulted in 2 recommendations.

REPORT PUBLISHED

26-A-04-013.01 to CMS - Open Unimplemented
Update expected on 05/17/2026
We recommend that the Centers for Medicare & Medicaid Services work with the MACs and other CMS contractors to continue reviews of dermatologists' claims for E/M services performed on the same day as a minor surgical procedure, which could have resulted in an estimated cost savings of $62,915,655.

26-A-04-013.02 to CMS - Open Unimplemented
Update expected on 05/17/2026
We recommend that the Centers for Medicare & Medicaid Services work with the MACs and other CMS contractors to continue to educate dermatologists on Medicare requirements for billing E/M services, including maintaining sufficient information to support that the E/M services were performed and billed at the appropriate service level and using modifier 25 appropriately when billing E/M services performed on the same day as a minor surgical procedure.

View in Recommendation Tracker