An internal audit finds repeated use of modifier 59 to bypass NCCI edits when operative notes show only inherent component work. What compliance risk does this pattern primarily represent?
Select an answer to reveal the explanation.
Short Explanation
Modifier 59 is not a tip jar. Using it when the work was never separate is unbundling theater—and auditors notice the pattern.
Full Explanation
Misuse of distinct-procedural-service modifiers to defeat NCCI edits without supporting documentation constitutes improper unbundling. Revenue integrity audits target this pattern because it can inflate payment for services already included in a comprehensive procedure. The issue is coding compliance and potentially false claims risk, not privacy or teaching-physician attestation per se.