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CPT 27760 with E&M

What criteria do you use for billing an new patient E&M (99204-57) visit with CPT 27760 (Closed treatment of medial malleolus fracture; without manipulation-90 day global?)
We treated a patient for a left ankle fracture, he was seen at an outside ortho diagnosed and treated with a cam boot. He presents to us with pain that occurs when weight-bearing. We placed as short cast and will follow-up in 3 weeks.
Radiographic images were taken by the outside ortho and we reviewed them. We performed a History, PMH/FH/SH, ROS, and exam. Just because we performed the elements of the HPI/Exam and MDM does that justify the billing of the E&M?

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