Question Can we bill for E/M code to the insurance/HRSA for the pt who received covid19 vaccine?

sjooemmy08

Networker
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Los Angeles, CA
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Hello everyone.
I work for an FQHC, and we recently started giving out covid-19 vaccines to our patients.
Some patients are covered by Medi-Cal or Medicare, but some are uninsured.

So the problem starts when my boss called me and asked shouldn't we bill for the
E/M since we do vital and exam patients prior to administration of the vaccine.

The rendering provider is our NP, who is eligible to send out bills under her name.

To my understanding, if the provider actually saw the patient for the overall exam AND gave
the vaccine we would be able to bill for it to the insurance companies. If the encounter was
to only vital and administer the vaccine, we should not bill for an E/M.

However, if the patient is uninsured we shouldn't bill for an E/M code to HRSA.

Please advice!
 

thomas7331

True Blue
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You should not bill an E/M if the only reason for the exam and taking of vital signs was to determine the suitability of the patient for vaccination - that E/M would be considered inclusive to the administration of the vaccine.

If the patient requires E/M above and beyond what it routinely necessary for the vaccination, and documentation supports the use of a modifier 25 to show this, then it may be appropriate to bill an E/M in those specific cases only.
 
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Hi there, I just wanted to add that the HHS Office of Inspector General has issued several notices reminding vaccine providers not to charge patients. For example:

The COVID-19 Vaccine Is Provided at 100% No Cost to Recipients. All organizations and providers participating in the CDC COVID-19 Vaccination Program:
  • must administer COVID-19 Vaccine with no out-of-pocket cost to the recipient;
  • may not deny anyone vaccination based on the vaccine recipient's coverage status or network status;
  • may not charge an office visit or other fee if COVID-19 vaccination is the sole medical service provided;
  • may not require additional medical services to receive COVID-19 vaccination;
If there's something truly separate make sure it is clearly documented because providers are going to be audited (if the audits haven't started already).
 

sjooemmy08

Networker
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Location
Los Angeles, CA
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You should not bill an E/M if the only reason for the exam and taking of vital signs was to determine the suitability of the patient for vaccination - that E/M would be considered inclusive to the administration of the vaccine.

If the patient requires E/M above and beyond what it routinely necessary for the vaccination, and documentation supports the use of a modifier 25 to show this, then it may be appropriate to bill an E/M in those specific cases only.
This is exactly what I thought it was! Thank you
 

sjooemmy08

Networker
Messages
25
Location
Los Angeles, CA
Best answers
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Hi there, I just wanted to add that the HHS Office of Inspector General has issued several notices reminding vaccine providers not to charge patients. For example:


If there's something truly separate make sure it is clearly documented because providers are going to be audited (if the audits haven't started already).
Oh, we are not charging patients for anything.
My boss wanted to know if we can bill Medi-Cal and Medicare for EM code along with the covid vaccine administration code.
 
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