RN Counseling Contribution to Physician E&M Coding

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While doing E&M code audits we have came across the question that pertains to Registered Nurses (RNs). Specifically, do their counseling sessions contribute to the calculation or justification of the Physician's Evaluation and Management (E&M) code?

We understand that RN counseling contributes to the patient's overall care. However, if a physician bills for an E&M code where an RN exclusively conducted the counseling—for example, regarding birth control options—can the physician still bill for that E&M code based on the RN's documented counseling? We need clarification on whether RNs qualify as Qualified Healthcare Professionals (QHPs) according to AMA/CMS guidelines in this context.

Your insights on this matter would be greatly appreciated. Thank you!
 
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