This is definitely illegal. 9921X is for a problem oriented medical visit and requires a diagnosis (chief complaint) and it is clearly spelled out in the guidelines. If the patient is coming for the annual, to obtain payment, your employer is likely using an unreported chief complaint. This is a textbook definition of a false claim. They can charge reduced fees if they want to help but to compromise his/her license is crazy and not recommended.
There may be situations where the patient has a history that warrants a Pap (abnormal results/PAP). I would recommend using those dx code with the PAP.
Good luck, I encountered this situation before and left the practice because, unlike a physician, I will likely be unable to afford a high priced attorney to keep me out of jail. (Yes, they prosecute coders for fraud too).
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