# COMAR Title 10 — Maryland Department of Health

## Subtitle 40 — Board of Podiatric Medical Examiners

### Chapter 08 — Interpretation of Terms in the Maryland Podiatry Act

#### Regulation .03 Examples of Fragmentation of Billing.

*COMAR 10.40.08.03*

A. By way of illustration, but not limitation, fragmentation of billing in Regulation .02B(3)(i), of this chapter, includes breaking the following general procedures into the following listed specific procedures:

  (1) Keller bunionectomy — a multi-step procedure, which may include any or all of the following:

    (a) Resection of medial eminence 1st metatarsal head;

    (b) Resection base of proximal phalanx;

    (c) Capsulotomy/capsulorrhaphy;

    (d) Z-plasty of extensor tendon; and

    (e) Sesamoidectomy.

  (2) Lesser metatarsal osteotomy — a multi-step procedure, which may include any or all of the following:

    (a) Tenoplasty;

    (b) Capsulotomy/capsulorrhaphy;

    (c) Osteotomy; and

    (d) Fixation.

B. Fragmentation of billing is especially egregious when the licensee bills for both the general and specific procedures.