Can a Registered Dietitian bill an E&M?


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I work for a pediatric practice who employs a registered dietitian for nutrition counseling. Currently, a provider sees the patient, recommends that the patient is seen by the dietitian, and then the dietitian provides the counseling. We bill the E&M for the level of service the physician provides, and then 99401-99404 depending on how much time our dietitian spends counseling the patient. We are wondering if once we have credentialed our dietitian, we could bill an E&M for her visit without the patient seeing the physician?

According to the 2017 CPT code book, an E&M can be billed by "physicians and other qualified health care professionals who may report evaluation and management services reported by a specific CPT code(s)." The next section states "A 'physician or other qualified health care professional' is an individual who is qualified by education, training, licensure/regulation (when applicable), and facility privileging (when applicable) who performs a professional service within his or her scope of practice and independently reports that professional service."

We feel that a registered dietitian fits that description, but I just wanted to see if we are thinking about this incorrectly.

Thank you so much!


True Blue
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Evaluation and management codes aren't appropriate for reporting dietician services - these codes are for diagnosis and treatment of medical problems which is outside of a dietician's scope of practice. Medicare limits payment for E&M to physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse midwives (in addition to physicians) and won't pay for other provider types such as psychologists, audiologists, physical therapists as well as dieticians. I believe that the only codes Medicare currently pays for MNT services performed by dieticians are 97802, 97803, 97804, G0270 and G0271. Commercial and Medicaid payers may have additional codes they allow but I would not recommend using E&M codes for dietician services unless the payer has a written policy that requires it.


True Blue
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Dietitians have their own subset of codes to report their services and they more accurately describe the services being performed (they are time based as well). The time component of an E&M is only there to bump up the level not replace the components of an E&M.