Know Status of RN When Calculating E/M Level
Question: I work at an office that prescribes birth control. Sometimes, registered nurses (RNs) counsel patients on birth control options in anticipation of a physician or nurse practitioner (NP) putting in a prescription. Can I count the RN’s documented counseling toward the physician’s evaluation and management (E/M) leveling and code selection for the appointment? Michigan Subscriber Answer: The CPT® code book frequently describes roles and responsibilities that qualified health professionals (QHPs) can perform but does not provide a single definition for who, exactly, qualifies as a QHP, often leaving the designation to states via scope of practice. However, the code book is more explicit regarding clinical staff: “A clinical staff member is a person who works under the supervision of a physician or other qualified health care professional 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.” Accordingly, one way to designate a QHP from clinical staff could be checking whether the provider in question has a national provider identifier (NPI) and can bill under their own name/NPI. RNs generally would be considered clinical staff, so you could possibly bill the RN’s time as an incident-to service — if all the respective criteria is met. However, when counting time to establish the E/M level, you cannot use clinical staff’s contribution in your calculations — time should include only what’s spent by the physician or QHP. Rachel Dorrell, MA, MS, CPC-A, CPPM, Production Editor, AAPC
