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Required Physician EXAM for future billable events?

Hello, I’d like some input from the E/M experts. Our coders were given a directive that if the Physician does not perform a Physical exam on the Initial consultation OR any other established face to face visit such as a ‘weekly status check’ during course of treatment, then any and all follow up EM services (incident to) or otherwise are not billable.

We have physicians who may not perform an initial exam, therefore, not meeting 3 out of 3 required elements (HEM) and we don’t bill for the EM. Then the patient returns for follow up to discuss treatment, review tests, start treatment, etc. and if the physician meets the 2 out of 3 requirements, with still NO exam, we were told, we cannot bill the established patient visit until the physicican performs an exam.

I belive this is incorrect, and I’d like some feedback.

Thanks!

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