Wiki established patient?

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If a patient was seen 3 years and 10 days ago by the same provider, is he still an established patient? Does it have to be exactly within 3 years or less, or can it be few days over? I can't find a reference for this.
 
No the patient would not still be established. As long as it has been over 3 years, the patient can be billed as a new patient.
 
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