Can NP's bill 99214 and 99215 as incident to?


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I cannot find anything to state that they cannot bill 99214 or 99215, just that it must be carefully decided before they do since it's moderate and high complexity.

Can anyone help me with a souce to tell me either way?

Thanks so much


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I see no reason why they couldn't do a 99214 as incident to. You have an established patient with 3 chronic conditions and Rx management, no reason that couldn't be billed incident to if the treatment was established by the doctor.

I am having a hard time seeing how you could get a 99215 incident to. I know established are 2 of 3, and NP are usually really good at getting a lot of history documented and doing very extensive exams. So comprehensive history and exams are not uncommon, in my experience with NPPs. The problem would be the medical necessity piece.

On the flip side if it was met using MDM, my thinking is high complexity is probably going to be a new problem and not meet the incident to requirements.

To my knowledge there is nothing that states NPs can't bill those codes incident to. They will just direct you to what the state allows and the incident to requirements.

Laura, CPC


True Blue
Columbia, MO
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I agree with Laura, as long as incident to requirements are met, in that the physician is on site and this is not a new problem. I have however been in some states where the NPs have told me that there is a regulation in that state that prohibits Np consults and level IV and V visits, However like you I have never seen this in writing for myself. I would think however that your NP would know so I would ask them, and then maybe inquire with your payers.