The Centers for Medicare & Medicaid Services (CMS) and the Office of Inspector General (OIG) have reviewed the use of Modifier 25 to unbundle payments for evaluation and management (E/M) services when a procedure is performed. In the 2017 Medicare Physician Fee Schedule Proposed Rule, CMS has identified 83 target codes for review. Modifier 25 should only be used when services are provided beyond those considered to be part of the procedure performed. The over use of Modifier 25 was noted by the OIG in 20052. In the 2005 report the OIG found that 35% of the claims using Modifier 25 did not meet the billing guidelines, resulting in improper payments. The specific listing of the 83 target codes in the 2017 Proposed Rule could mean increased auditing of the use of Modifier 25.