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Rabies Vaccine

Our local health department is no longer carrying the rabies vaccine. The patients require 3 visits for the vaccines, which is ordered by our ER physician. Can we bill the 99281 along with the administration fee and drug charge for the administration of the drug at our ER? The patients vitals are being taken and recorded and corresponding documentation as to the injection site and reaction.
 
How we do it at the ED I work for is:

1st visit: Bill for the immunoglobulin (90471), vaccine (96372), and levels with the dx codes Z20.3 and Z23. The levels we do is Facility 99283-25 and Profee 99284.

2nd and 3rd visits: Bill only for vaccine with dx code Z23 with no e/m levels (no charge visits)
 
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