Per AAFP
Prothrombin time testing with 99211
Q
I am considering adding CLIA-waived fingerstick prothrombin time testing to my outpatient clinic services. In addition to charging for the fingerstick (36416) and the test (85610), can I also bill a level-I office visit to cover my nurse's involvement in obtaining the specimen, running the test, processing the results and adjusting the warfarin dose?
A
It depends. If your nurse provides a medically necessary E/M service to the patient and if your payer has a policy that allows the reporting of E/M services by nurses under the supervision of a physician (e.g., Medicare's incident-to billing rule), you may report a 99211 in addition to 36416 and 85610. Check with your private payers to determine whether they have an incident-to rule in place.
Reports from Medicare audit contractors have noted that the documentation for these types of visits often fails to indicate medically necessary E/M services, which has led to the denial of 99211 services. To meet the requirements for a 99211 visit, nurses should document the reason for the visit, changes in the patient's history, medications or diet, instructions for continuing the physician's plan of treatment, and any discussion that occurs. For more guidance, see ?Understanding When to Use 99211,? FPM, June 2004, and ?The Ins and Outs of ?Incident-To? Reimbursement,? FPM, November/December 2001.
You should also check which payers reimburse anticoagulation management under codes 99363 (for the first 90 days of therapy) and 99364 (for each subsequent 90 days of therapy). These codes include the physician review and interpretation of test results, patient instructions, dosage adjustment (as needed) and ordering of additional tests. When reporting 99363 and 99364, you may not report an E/M office visit code. (Note that Medicare does not reimburse the anticoagulation management codes in 2007, and the proposed rule for 2008 still lists them as noncovered.)
http://www.aafp.org/fpm/2007/1100/p15.html#fpm20071100p15-sa3
Hope this helps!
Stephanie Walker, CPC
