Modifier 25 is only two digits, but it can reveal whether the workflow behind the claim is actually under control.
HHS OIG has repeatedly scrutinized same-day E/M billing, and in 2026, a related review remains active on its Work Plan. This is not a minor coding detail. It is a control test.
I’m Tyling Batista, and this is Documentation Defense 360™ Coffee Breaks. Three minutes, one documentation risk, and one practical move.
Modifier 25 is appended to an evaluation and management code when a medically necessary, significant, and separately identifiable E/M service is performed on the same day as another procedure or service.
The record must support the reported E/M level and show work above and beyond what is normally included in that procedure. That sounds straightforward. Operationally, it often isn’t.
If Modifier 25 usage clusters around one provider, location, procedure, or template, it may point to inconsistent education, default charge capture, weak claim edits, or documentation that does not support the claim. Even the absence of Modifier 25 can reveal a control failure.
The current OIG review is examining same-day E/M claims that were paid without it. So, do not ask only, ‘Are we using Modifier 25 too often?’ Ask, ‘Can we consistently defend when we use it and recognize when we should?’
Here is one practical move your organization can make. Run a 90-day Modifier 25 control review.
Stratify the data by provider, location, procedure, specialty, and payer. Identify both high and low utilization patterns. Then review a focused sample from each group.
For every claim, ask: Can a reviewer clearly identify the separately identifiable E/M work? Does the assessment and plan show work beyond what was required to perform the procedure? Does the documentation support the E/M level reported? And would the claim remain defensible under the applicable payer’s rules?
Then trace the claim backward through the note template, charge capture, coding, edits, and final submission. Modifier 25 failures are often workflow failures, not simply physician failures.
The leadership question is this: Can we explain our Modifier 25 pattern as a clinical pattern, or has it quietly become a billing habit?
Modifier 25 should never be automatic, and it should never be avoided simply out of fear. It should be earned by the work performed and supported by the documentation.
When the clinical record, the code, and the control environment all agree, you protect both compliance and appropriate reimbursement. That is Documentation Defense.