Wiki Can an RN perform a 99201 and an MD sign off and bill as if the MD was the performing provider?

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The DOS is prior to 2021. The setting is an outpatient clinic and the CC is, "Nurse Intake. Patient presents for chronic conditions. Please see A&P for HPI and other details." The RN will conduct a full visit; HPI, ROS, Exam, and assessment. For each condition addressed, RN will detail lab orders, referrals, or other plans. The RN does not have an advanced practice license, nor an NPI, and the MD will sign off on the note and bill it as if they (MD) performed the E/M themselves. The MD will later conduct another E/M, usually a 99214, within a week or two of the RN performing the 99201. So the question is, can an RN perform a 99201 E/M, or does a new patient E/M require an MD? Statements within the RN's assessment indicate MD is not present.
 
No, absolutely not. New patient visits never qualify for 'incident to' billing. The MD or NPP must personally perform any new patient E/M service.

In addition, an RN cannot diagnose a patient so they cannot confirm whether or not a chronic condition still exists at the encounter. Doing this, and writing 'lab orders, referrals, or other plans' on a new patient who hasn't yet been seen by the provider is quite likely acting outside the scope of their license.
 
No, absolutely not. New patient visits never qualify for 'incident to' billing. The MD or NPP must personally perform any new patient E/M service.

In addition, an RN cannot diagnose a patient so they cannot confirm whether or not a chronic condition still exists at the encounter. Doing this, and writing 'lab orders, referrals, or other plans' on a new patient who hasn't yet been seen by the provider is quite likely acting outside the scope of their license.
Thank you, I appreciate the quick response. I am auditing records where the RN is performing new patient intakes. What I am hoping for is a guideline or guidance I can cite or reference please?
 
check your state board of nursing for their scope of practice. No RN can diagnose.

Also, look at the CMS manual, particularly the incident-to guidelines. Even if your RN could diagnose (and she can't), you are violating incident-to guidelines. (no new patients, must have an established treatment plan, etc.).
 
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