A provider sees a patient for a scheduled procedure. A separate problem comes up mid-visit, gets evaluated, and the practice bills both services with Modifier 25 attached. The claim pays, and everyone moves on, until that same claim gets swept into a targeted payer audit because the documentation never actually supported a separate, significant E/M service. The three failure patterns 1. Routine pre-procedure work billed as a separate visit: Baseline assessment before a procedure, confirming the patient is appropriate, reviewing labs, checking vitals, is part of the procedure. It is not a separate E/M, and Modifier 25 does not apply just because something happened before the procedure. 2.Cloned or thin documentation: An assessment and plan identical to the note from two visits ago, or a problem mentioned in one line with no distinct plan, will not survive a payer review. The documentation has to show medical decision-making distinct from, and above and beyond, the procedure. 3. Modifier 25 used to override a denial: A claim gets bundled and denied, someone appends Modifier 25 and resubmits, and it pays. If the documentation never supported a separate E/M, that resubmission was not a correction. It was a workaround, and it is exactly the pattern payer audits look for. The global period trap Global periods run 10 days for minor procedures and 90 days for major surgeries. During that window, routine E/M care for the same procedure is bundled and not separately billable, even with Modifier 25 attached. A genuinely unrelated new problem may have a path to separate billing, but it needs documentation of the unrelatedness and compliance with payer-specific global period rules. Procedural specialties, surgical groups, orthopedics, gastroenterology, dermatology, OB/GYN, carry the most risk here. The five-question audit test 1. Was a significant E/M service actually performed, beyond the usual work of the procedure? 2. Is the separate problem, assessment, and management clearly visible in the documentation? 3. Would the E/M have been separately reportable if the procedure had not occurred that day? 4. Do current NCCI, global-period, and payer-specific rules allow Modifier 25 here? 5. Could the practice defend this claim on the medical record alone, not just the modifier? Three actions this week • Pull 20 to 30 Modifier 25 claims from the last 90 days across your most frequent providers and run each one through the five-question test. • Where claims fail, start with provider education, one conversation with examples from their own documentation, not a policy memo. • If more than 20 percent of the sample fails, add a pre-release review for high-frequency or high-risk providers for 60 to 90 days while the pattern corrects. Episode breakdown • The setup: what Modifier 25 is actually supposed to communicate • The three failure patterns • Three cases: yes, no, or verify • The global period trap • The five-question audit test • Running your own Modifier 25 practice audit