Wiki Billing 99211 and an injection but NOT an injection administration code

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Okay, so I have a really tough question that I am having a hard time finding the answer to. We have a clinic that provides injections for substance abusers. Generally speaking, when a patient comes in specifically for an injection, we would not bill 99211 but rather the 96372 for the injection admin. I am being asked about this: "What I am understanding after some discussion with XXX, RN, is that she is doing E&M (such as limited Review of Systems, observational physical assessment, education about the chronic condition, review of labs, and/or ordering of labs) outside of the injection at some visits. So, some of these visits are NOT truly injection only visits; this work would meet criteria for 99211, except that we cannot bill both the 99211 and the 96372 together. So, my confusion is around why we wouldn't be able to choose to bill the 99211 instead of the 96372 in cases where documentation justifies that E&M was done.

Is it correct coding/billing to bill the 99211 for the nursing visit, and then the injection code without the injection administration code? Can we "choose" to bill the nursing visit in these cases?

Any help would be much appreciated. I've been all over CMS and can't find any guidance for this particular scenario.

MaryAnne
 
Yes, you can bill a 99211 instead of the 96372 if all the required criteria are met, including physician supervision
 
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