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dballard2004

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In 2012, the AMA issued the CPT Corrections Document that now clarifies the term "other qualified healthcare professional" that is used throughout the CPT manual. Per the CPT Corrections Document, which can be accessed here:http://www.ama-assn.org/resources/doc/cpt/cpt-corrections.pdf, "other qualified healthcare professional" is now defined as a healthcare professional whose education, state laws, licensure, etc., allows him/her to perform services and who can independently report the service. Clinical staff are excluded from this because they have to work under the supervison of a physician and can't independently report their services.

Now, here is my question.....when I read the description of codes 98966-98968 for telephone services by nonphysicians, it clearly states "qualified health care professional." If I am intrepreting the AMA defintion correctly, this means that the nursing staff can't report these codes since clinical staff are not considered "other quaified healthcare professionals."

Am I off base here? Is this how others are intrepreting this as well? If I am correct, then this guidance would also apply to codes 98960-98962 for education and training for patient self-management since the description of these codes state "other qualified nonphysician health care professional."

Thoughts?
 

gailmc

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No, you are not off base and are interpreting it the same way we did. Codes 98966-98968 should be used for NPPs - non-physician providers such as nurse practitioners, PA, etc.
 

dballard2004

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Thanks so much. I am wondering if the same guidance applies to codes 98960-98962 for education/training for patient self-mangement. The description of these codes also state "qualified nonphysician health care professional."
 

mitchellde

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No I disagree with your interpretation. Nurses and nutritionists etc are qualified non physician personnel. They do independently report what they do when write an official note on the chart. They cannot however independently BILL for their services which is entirely different. NPPs use the same phone call codes as the physician. 98960-62 are for nurses and nutritionists, and therapists. Look at the codes and the descriptions again. As well as the instruction notes.
Nurses and techs administer injections all the time and you Bill with a 96372 you are not billing under the nurse for these you ate billing under the doctor. Tje nurse provides this service independently yet under physician supervision and you Bill under the physician, yet the nurse documents the service.
 

dballard2004

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My intrepretation of "independently report the service" means in the billing sense. If you read the document, it clearly states that "other qualified healthcare professionals" are distinct from the clinical staff in the fact that the clinical staff do not independently report his/her services.

I welcome other opinions.
 

mitchellde

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My interpretation of independently report the service is being able to officially document their service in the medical record. A nurses aid does document their service in the medical record a nurse does so does a therapist and a nutritionist. They independently report their service, even though they cannot independently bill their service. per your definition then how would you bill for an injection which can be administered by qualified non physician personnel. It is reported in the chart note by the nurse but billed under the doctor.
 

dballard2004

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I have posted this question on another forum to get other coders who are not affiliated with AAPC opinions on this issue. I will post the outcome.

My thanks to all who replied here. I welcome and respect all opinions.
 

mitchellde

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There was a CPT changes book the year these codes went active which would have been 2008, and in that book I believe there was a more thorough discussion regarding the usage of the phone call codes. I had a copy back at the time but sadly it is now missing.
 

dballard2004

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In 2008 when these codes were created, the intent from CPT may have been for the ancillary staff to report these codes, but in 2012, CPT clarified the term "other qualified healthcare professional" to include the above as in my original post. This is leading me to believe that the ancillary staff can no longer report these codes as well as codes 90460/90461 for pediatric vaccine administration.

Let me rephrase my question......the AMA has clarified the defintion of "other qualified healthcare professional" in the 2012 CPT corrections document (see the link above in my original post). How are others intrepeting this new defintion? I intrepret this to mean that any codes with the description "other qualified healthcare professional" can't be reported by the ancillary staff since the AMA specifically states that clinical staff can't independently report their services.

Thoughts?
 

mitchellde

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as long as the ancillary staff is a qualified medical personnel, I really think this clarification is to mean not office personnel. I know in some small offices the receptionist does vital signs and weights and answers phone calls and everything else. They typically have no license or certification they just learn on the job and do what needs to be done. These are not qualified ancillary medical professionals but you nurse is. They specifically used the word "report" their services, not "bill" their services. They are 2 different things, a service is reported as rendered when it is documented in the medical record, if the person has no medical credentials then they are not to be documenting services in the chart.
I truely think you are reading way too much into the definition.
 

dballard2004

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To give an update on this post.....

I posed this question on another forum because I was interested in other coder's opinions outside of AAPC. The response that I received seems to validate my intrepretation that "other qualified healthcare professional" means one who can independently bill for his/her services. CPT codes 98966-98969 cannot be reported by ancillary staff. These codes should only be reported by NPs, PAs, PTs, psychologists, etc. In other words, one who independently bills for his/her services. Going forward, we will be discussing this issue at my clinics and changing our education around the use of these codes.

I do realize that other's opinions on this issue are different, and I respect that.
 

dballard2004

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As another side note......this new guidance also impacts codes 90460-90461 for pediatric vaccines. Again, the description of these codes state "other qualified healthcare professional." In order to report these codes, there must be vaccine counseling that occurs with the patient/parent, etc. prior to the vaccine administration. The counselng must come from the physician, NP, or PA in order to report these codes. Based on the new guidance, if a nurse or MA does the counseling, you would have to report codes 90471-90474 instead.

I am also thinking that this new guidance will impact codes 98960-98962 for education/training for patient self-management as the description states "other qualified non-physician healthcare professional."
 
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