99211: Not So Simple

99211: Not So Simple

Check your nurse’s credentials and payer incident-to rules before billing this E/M service.

By Karla M. Hurraw, CPC, CCS-P
CPT® 99211 Office or other outpatient visit for the evaluation and management of an established patient that may not require the presence of a physician or other qualified health care professional. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services is sometimes referred to as a “nurse visit,” probably because the code description specifies that the service, “may not require the presence of a physician or other qualified health care professional.” Offices often use this code for any service that a nurse provides, but this is not always appropriate.
Consider Credentialing Clinical Staff
If your nurse is credentialed and is billing using his or her own National Provider Identifier (NPI), he or she may report 99211. If your nurse is not credentialed, however, and bills under the provider’s NPI, the service must meet incident-to requirements. The nurse must follow an established, written care plan for that particular patient, to which there may not be any changes.
Note: Every payer I contacted when writing this article confirmed that a service provided solely by clinical staff must meet incident-to requirements to be billed under the provider. Payers differ, however, so it’s best to check with your individual payers to confirm their policies.

  • A patient presents for a prothrombin time and international normalized ratio (PT/INR). A nurse performs the test, gives the results to the provider, and relays a medication change to the patient. The visit no longer meets incident-to requirements because there was a change in medication. You may not bill 99211; you may bill only the PT/INR. To bill for the evaluation and management (E/M), the provider must have seen the patient.
  • A nurse performs a urinalysis (UA) for a patient with symptoms of urinary tract infection, relays the results to the provider, and gives the patient a prescription. Here again, incident-to requirements aren’t met: There is likely no applicable, written plan of care, and a new medication was prescribed. You cannot report 99211; you may only charge for the UA.

Tip: The best solution to avoid such cases is to credential your nurses (if the payer allows it).
Medical Necessity Is a Necessity,
Even for Low Level Visits

Don’t forget the role of medical necessity when reporting 99211.
For example, a patient has an established diagnosis of hypertension. The provider documents that the patient should return for a blood pressure check with a nurse in one week, and the patient does so. The nurse measures the patient’s blood pressure, which is normal, and sends him on his way.
Does this substantiate billing a 99211? Was an adequate E/M performed?
Most offices feel that charging for this service is not appropriate. You might even consider instituting an office policy stating that a credentialed provider will see all patients, and that only certain services (such as prearranged injections and quick blood pressure checks) are eligible for nurse visits. Injections are reimbursed through the injection fee, and an occasional quick blood pressure check could be considered a courtesy to the patient.
Karla M. Hurraw, CPC, CCS-P, is lead coder at DeKalb Health Medical Group in Auburn, Indiana, and holds a degree in Medical Office Administration. She is a member of the Fort Wayne, Indiana, local chapter.

Evaluation and Management – CEMC

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Renee Dustman, BS, AAPC MACRA Proficient, is managing editor - content & editorial at AAPC. She holds a Bachelor of Science degree in Media Communications - Journalism. Renee has more than 30 years' experience in journalistic reporting, print production, graphic design, and content management. Follow her on Twitter @dustman_aapc.

12 Responses to “99211: Not So Simple”

  1. Misha Diden says:

    The examples provided in this article contradict Medicare and other payer guidance regarding the appropriateness of coding 99211. These scenarios are typically used when explaining the correct way to use 99211.

  2. Chris says:

    I would like to start a patient on testosterone replacement therapy. I have worked in testosterone clinics where the patients came in every week for an injection, a very quick office visit was performed by the provider, and then the injection was given and it was billed as a 99213. They had a lot of trouble with reimbursements, and I would like to avoid this hassle, but would like my patients to have an injection every week. I am not sure a 99213 is appropriate, but I do want to be paid for our services. Basically, the patient buys the medication, brings it with him to the office, we use our supplies and his testosterone vial, and the nurse gives him the injection. How should this be billed?

  3. LM says:

    @ Chris – It is a pre-planned procedure, you would only bill the administration (96372) and you should have no issue with reimbursement. If the patient wants to discuss an un-related issue and sees the provider for this other issue, then you could bill the office visit with a modifier 25.

  4. S Cox says:

    Our MA sees our pre-surgical patients goes over all the documentation, explains what is going to happen the day of the surgery, discusses what the patient now needs to do clearances from their PCP & or cardiologist and gives them their paperwork. Can we bill the 99211 code for this visit?

  5. Mary Klumpstra says:

    An RN performs med checks in our office. We bill the 99211. If I am understanding correctly, if she discusses medication problems reported by the patient and the physician orders or changes medication, the nurse visit should not be billed? Can someone clarify this please, specifically as it relates to medication changes and/or RX. Could it be billed if the physician signs the note but still does not see the patient? Is the advice here in accordance with Medicare rules and policies?

  6. alex says:

    If patient comes into office and for medication review can a medical assistant under the supervision of a physician bill for 99211?
    Or if blood pressure needs to be checked can the medical assistant bill for 99212?

  7. Maria says:

    How do the two examples above not meet the incident-to requirements? Since in both the services, even provided by employees, are provided incident-to the physician’s services and the physician is on-site providing supervision criteria and I’m sure will document and sign off on the nurse’s clinical note, seems to me that they qualify to bill 99211.

  8. patricia gardnerbooth says:

    I would like to know if you are referring to hospital or Professional services relating to your article above.

  9. Tasha Vassar says:

    If a patient has an open wound and requires daily bandage changes, can a 99211 be billed for bandage changes done during the weekend? We have nursing staff 24/7 and an on-call physician. We would not bill these are incident to, but is it ok to bill them under the on-call provider?

  10. Ashley Brazzell says:

    If a patient comes in for pre-op & post-education done specifically by a nurse. Can this be billed for?

  11. Suzie says:

    Can CCM 99490 and 99211 be billed in the same month?

  12. David Newman says:

    can 99211 be used in a telephone visit? As in a post discharge assessment and care coordination call?