Oncology & Hematology Coding Alert

READER QUESTION ~ Check Payer Supervision Rules on 99211

Question: If a patient pays for her medicine and goes to the clinic for the nurse to give the injection, we can bill 90772 (Therapeutic, prophylactic or diagnostic injection [specify substance or drug]; subcutaneous or intramuscular). But CPT says we should bill 99211 (Office or other outpatient visit for the E/M of an established patient ...) if this visit takes place without physician supervision.

We used to bill an E/M code but stopped when we were told at a coding seminar a few years ago that we could not do this. What should we report?

South Carolina Subscriber
  
Answer: You cannot ever bill 99211 with 90772, according to a National Correct Coding Initiative edit that bundles 99211 into 90772, with a -0- modifier indicator. Remember: The -0- modifier indicator means that you cannot break the bundle.

You have two options:

Option 1: You report 90772 for the injection if a supervising provider is present in the office.

Option 2: You report 99211 instead if no supervising provider is present in the office. You should interpret -supervising provider- to mean any qualified supervising caregiver who can bill in their own right. This rule would only apply when a registered nurse (RN) is giving the injection, not the oncologist, nurse practitioner (NP), or physician assistant (PA). 

Snag: Though option 2 is technically the CPT instruction's intent, you-ll be hard-pressed to find a payer to reimburse 99211 if you don't meet -incident- to- requirements.

Heads up: You will also incur another problem if the RN gives the injection and you have no one who can supervise or is qualified to supervise if something goes wrong (called malpractice risk). 

Bottom line: If you perform the injection without direct physician supervision, consider this a free service.

You should also check your state's laws to be sure your practice may legally provide injections without physician supervision.
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