Avoid compliance traps that come when practices cluster E/M services
Clustering levels of E/M services is not new but continues to be a hot topic for CMS and the HHS Office of Inspector General (OIG). Clustering means billing all of your E/M services among one or two middle-level E/M services because you reason that some will be higher and some lower and the payments will average out in the long run -- that raises two big problems for you.
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