Wiki TB tests and the use of 99211

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Apprentice CPC here and I have been searching and searching for the answer to this question and am getting conflicting answers. I work in a student health clinic on a college campus and we provide TB testing and vaccines that are required for student programs such as nursing, surge tech, and medical assistant. Students often only use our clinic for these purposes and only see a medical assistant who administers the vaccines or performs the TB test.
When the student sees the MA for the TB test, I code for the skin test with 86580. Upon returning for the read, I have been told to code E/M code 99211. My problem is that most students are not seeing and have never seen one of our nurse practitioners so I do not feel that it is appropriate to use an established patient E/M code 99211 for a TB read done by an MA. We do not bill insurance and only code for tracking purposes but this one is driving me nuts because I want to be accurate in my coding.
 
From a purely coding perspective, you're correct - 99211 represents an E/M service ordered by a provider that is part of a plan of care for the management of a patient's problem. If this test is being conducted as a screening and/or as an administrative requirement and not as part of a provider's treatment plan, then a problem-oriented E/M service code is not appropriate.

But if you're using this just for tracking purposes and not for billing of claims, then there's no issue here because you're not actually using the code to represent anything to an outside entity for payment purposes. If your practice decides that the use of the code internally may be creating confusion or incorrect reporting within your organization, it might be better to select another code, such as a 'dummy code' that is specific to this particular situation. But from a compliance or correct coding standpoint there's no problem with substituting 99211 here as long as it's not going out on a claim.
 
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