Eli's Rehab Report

Reader Questions:

99211 Is Not for Nurses Only

Question: We employ a physician assistant (PA) who performs all levels of E/M codes. We recently noticed that if he sees a patient just for a blood pressure check, he bills 99212. We think he's upcoding because those visits only require 99211. He says 99211 is for nurses only. Who is correct?

Georgia Subscriber

Answer: Your physician assistant is incorrect. Just because 99211 (Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician. Usually, the presenting problem[s] are minimal. Typically, 5 minutes are spent performing or supervising these services) is the only E/M code that registered nurses can bill does not mean that it is a "nurses only" code.

Correct coding dictates that you bill for what you perform, and if a physician, physician assistant, nurse or any other licensed medical professional sees a patient for just a blood pressure check and then leaves the room, he or she should probably bill only 99211 because the service performed or documented did not meet the requirements for 99212 (Office or other outpatient visit for the evaluation and management of an established patient usually the presenting problem[s] are self-limited or minor. Physicians typically spend 10 minutes face-to-face with the patient and/or family).

Even though 99212 is a lower-level visit, it still requires two of the following three components: a problem-focused history, a problem-focused examination, and straightforward medical decision-making.

If the PA's visit did not meet these requirements and the U.S. Office of Inspector General (OIG) sees that your PA consistently bills standard blood pressure checks this way, you could face problems if the OIG audits your records. Remind your staff that they should bill for the services they perform, no matter how much medical training they have.

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