Following Medicare's guidelines, a 99211 could be billed by a PA (not an RN) if the "incident to" requirements are met. However, for "incident to" services, a physician must be present in the office suite...you indicate your physician was not in the office suite at the Time of Service. Also, 99211 must consist of both the evaluation and management elements. Based on your scenario, the RN would not bill a 99211.
Zaida V. Aquino, CPC
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