Policy & oversight
CMS Tells Dermatologists to Document Same-Day Visits Carefully Before Billing Them Separately From Procedures
A compliance notice in the August 27 MLN Connects newsletter reminds skin care providers that Medicare's global surgery rules bundle most same-day evaluation and management services into the procedure payment unless strict documentation standards are met.
By the Goodsurance editorial teamAugust 27, 2026
The Centers for Medicare and Medicaid Services published a compliance notice this week reminding dermatologists to bill correctly when performing both an evaluation and management service and a minor surgical procedure during the same patient visit.
Under Medicare global surgery rules, an evaluation and management service on the same day as a minor procedure is generally included in the single global payment for that procedure. A provider may bill the two services separately only if the evaluation and management service was significant and separately identifiable from the decision to perform the procedure. In that case, the provider must append Modifier 25 to the evaluation and management billing code and support the separate service with clear, independent documentation in the medical record.
CMS reminded dermatologists: billing a same-day office visit and minor procedure as two separate Medicare charges requires solid, independent documentation.
The guidance appears in the August 27, 2026 edition of the MLN Connects newsletter. It follows a November 2025 Office of Inspector General report that reviewed dermatologist same-day billing from 2019 and 2020. That review found a 10 percent error rate and estimated that Medicare made about 62.9 million dollars in overpayments for evaluation and management services that did not meet program requirements. The OIG recommended additional provider reviews and education; CMS did not concur but said comparable compliance efforts were already under way.
For Medicare patients, the guidance is a reminder that a dermatology visit where a minor procedure is also performed should generally result in a single bundled payment. Any separately billed evaluation and management charge must reflect a genuinely distinct service, not simply the decision to perform a procedure that was already planned.
In plain words
If you go to a dermatologist and also get a small skin procedure done at the same visit, Medicare usually pays for both together as one charge. A doctor can only bill for two separate things if the office visit covered something different from the procedure, and the doctor must write it down clearly. A federal watchdog found about a 10 percent billing mistake rate, and Medicare sent a reminder this week telling skin doctors to follow the rules carefully.
Understand the basics first
Source: CMS MLN Connects
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