Only exam is vitals?
You MUST meet all three key elements, including an exam, for all new patient codes.
If your only "exam" is vitals that might qualify for a 99201. But I'd need to see the rest of the documentation to be sure. If the physician documented total time spent face-to-face, and that more than half that time was in counseling/coordination of care, you could use time to determine the level of new patient visit (10 minutes for 99201).
I think the best policy is to have a "meet and greet" interview that you never bill out to any insurance. You tell the potential patient up front that this is not a covered service by insurance and that the patient will be expected to pay for the service at the time of the interview. The whole encounter could take place in the doctor's office. You might want to create a "dummy" code for tracking purposes.
If the patient has health issues that s/he wants addressed, s/he will have to make an appointment for a new-patient visit ... full history, appropriate exam, appropriate MDM.
F Tessa Bartels, CPC, CEMC