99215 CPT Code: Surviving a Medicare Audit

Last Updated: July 7, 2026

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Many providers intentionally under-code to a 99214 out of fear of a Medicare RAC audit. However, if the patient's condition warrants high-complexity decision making, CPT 99215 is absolutely justified.

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When to Bill 99215

To support a 99215, the Medical Decision Making (MDM) must be "High". You must meet 2 of these 3 criteria:

  • 1 or more chronic illnesses with severe exacerbation, progression, or side effects of treatment, OR 1 acute or chronic illness that poses a threat to life or bodily function.
  • Extensive amount and/or complexity of data to be reviewed.
  • High risk of morbidity from additional diagnostic testing or treatment (e.g., decision for major surgery, drug therapy requiring intensive monitoring for toxicity).

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Medical Necessity

The diagnoses on the claim must reflect severe or highly complex conditions. Routine hypertension without exacerbation will instantly fail a 99215 audit.

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Billing with Prolonged Services

If you bill 99215 based on time (40-54 minutes), and you exceed 55 minutes, you may be eligible to bill a prolonged service add-on code. Run an NCCI check to ensure correct modifier usage.

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