Wiki 99211 with INR

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I am struggling with this I have started coding for outpatient hospital family practice and we are doing INR's and I am being told to add a 99211 with the 36416 and 85610 if meds are changed. I have done research on this and I find this to be "incident-to" which when I look up the guidelines for "incident-to" it say • The physician/NPP that provides the oversight may not bill for the services of hospital employees. Only the hospital may bill for the services of hospital employees. So to me we can not bill the 99211 due to the hospital pays the ancillary staff not the physician. But when I talk to other codes they say according to the AMA CPT 2017 Professional book when you look up 99211 it says "that may not require the presence of a physician or other qualified health care professional. I am also being told that 99211 does not require face-to face? If any one can please help that would be great. Thank you very much.

https://med.noridianmedicare.com/we...-to-clarification-for-opps-and-cah-outpatient
 
This is a confusing area, but I agree with your interpretation. You cannot bill any 'incident to' services under the supervising provider's credentials if those services are performed in a facility. Medicare's guidelines specify that 99211 is for use for 'incident to' E&M services performed by employees of the physician, and based on this I agree that it is not appropriate to bill a 99211 to Part B in an outpatient facility setting if there is no face-to-face encounter with the provider. If you're coding for the facility, then you can bill the 99211 (or G0463 in the case of Medicare) on the facility's UB claim.
 
It says does not require the presence of the provider, however it does require the present of a qualified office person face to face. 99211 is a face to face service, the one providing the service must be either the provider or a qualified staff person that is an employee of the provider. So for services provided in the outpatient setting performed by facility staff personnel without a face to face encounter by the provider, there can be no provider charge. you also cannot bill for the lab draw if facility nurses performed that service and you cannot bill the lab fee if the facility lab performed that service. in short, if your office in in the outpatient clinic and your physician or physician employees did not render the service, there will be no physician office charges to code.
 
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