Revenue Cycle Insider

Question: One of our experienced registered nurses (RNs) regularly serves as an independent observer during outpatient procedures with moderate sedation. Can we bill 99151 to 99153 for their services?

New Mexico Subscriber

Answer: The CPT^® code book describes 99151 (Moderate sedation services provided by the same physician or other qualified health care professional performing the diagnostic or therapeutic service that the sedation supports, requiring the presence of an independent trained observer to assist in the monitoring of the patient's level of consciousness and physiological status; initial 15 minutes of intraservice time, patient younger than 5 years of age) to 99153 (Moderate sedation services provided by the same physician or other qualified health care professional performing the diagnostic or therapeutic service that the sedation supports, requiring the presence of an independent trained observer to assist in the monitoring of the patient's level of consciousness and physiological status; each additional 15 minutes intraservice time) as involving a “qualified health care professional” (QHP) performing the services and an “independent trained observer” to assist in monitoring.

According to the AMA, a QHP is an individual who is qualified by education, training, licensure/regulation (when applicable), and facility privileging (when applicable) to perform a professional service within their scope of practice and independently report that professional service. These professionals are distinct from clinical staff.

A clinical staff member is a person who works under the supervision of a physician or other QHP and who is allowed by law, regulation, and facility policy to perform or assist in the performance of a specified professional service but who does not individually report that professional service. Roles considered “clinical” in this sense include registered nurses (RNs), licensed practical nurses (LPNs), and medical assistants.

Accordingly, an RN would not be able to bill for their contribution to the services described in codes 99151-99153. Usually, the provider performing the sedation services bills for these codes.

Rachel Dorrell, MA, MS, CPC-A, CPPM, Development Editor, AAPC