Our college health center is setting up an STI clinic with all face-to-face encounters performed by RNs under standing orders of supervising physician. I understand that this may be acceptable practice for established patients (99211), but they are also going to be seeing new patients and having nurses bill out 99201 under the supervising physician's NPI number even though no physician will be seeing or evaluating those new patients at these visits. Per CPT, E/M services can be rendered by physicians "or other qualified health care professionals." Can anyone please provide me with official references showing why RNs cannot be considered qualified health care professionals for 99201? This new internal policy is a mandate from our executive director, and my coding supervisor says we are to bill these out because it is not stated clearly anywhere that RNs are not qualified.