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99211 and Nurse Only Clinic

  1. #1
    Location
    Overland Park, KS
    Posts
    1,166
    Default 99211 and Nurse Only Clinic
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    This is going to sound like an odd question, but my company is giving me grief on this, so I'm looking for other opinions here, please....my company recently opened a clinic that is staffed only by nurses (RNs). There is no MD, PA, or NP onsite, just an RN. The clinic is very limited in scope of course because it is only a nurse on staff. Now here is the dilemma, the nurses want to code these visits using 99211 and my company agrees with this. I say that because there is no provider at all onsite, meaning no MD, PA, or NP, these patients never establish care to this clinic, so 99211 can't be used since this code is only for established patients. I am also looking at this as "incident to" guidelines are not being met either. I'm curious to know what others say here. Am I on the right track here? Thanks.
    Dawson Ballard, Jr., CPC, CEMC, CPMA, CCS-P, CPC-P, CRHC, AAPC Fellow
    Coder

  2. #2
    Default
    I completely agree with you Dawson.

    Who do they plan on billing under? I am not aware of anyone that credentials RNs as stand alone billable providers.

    Incident to is not met in 2 different ways, the most obvious no doctor is even there, and the fact there is no established treatment plan throws it out as well.

    Scary what people will justify in order to earn a quick dollar.

    Laura, CPC, CPMA, CEMC

  3. #3
    Location
    Overland Park, KS
    Posts
    1,166
    Default
    My thoughts exactly Laura. Thanks.
    Dawson Ballard, Jr., CPC, CEMC, CPMA, CCS-P, CPC-P, CRHC, AAPC Fellow
    Coder

  4. #4
    Location
    Columbia, MO
    Posts
    12,572
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    This indeed is scary. No you may not use a 99211 because it is not a nurse visit level it is a physician level. It is just the only level a physician is allowed to charge when some other qualified staff member is face to face with the physician carrying out physician orders froman established plan of care. I am curious as well as to whom these visit are to be billed under. The last time I looked a nurses liscense does not allow the nurse to assess and diagnose a patient for any condition.

    Debra A. Mitchell, MSPH, CPC-H

  5. #5
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    I agree with you and all the others on this one. No way can they bill 99211 in that situation!
    Walker Bachman, CPC, CPPM

  6. #6
    Location
    Overland Park, KS
    Posts
    1,166
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    Thanks everyone!
    Dawson Ballard, Jr., CPC, CEMC, CPMA, CCS-P, CPC-P, CRHC, AAPC Fellow
    Coder

  7. #7
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    Is there a doc overseeing them? Or a medical director? Are they nurse practitioners? Seems awfully odd if there is none of that in place.... and no way is that level acceptable if it is just a nurse......

  8. #8
    Location
    Overland Park, KS
    Posts
    1,166
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    No doc, no nothing. Strickly RNs only.
    Dawson Ballard, Jr., CPC, CEMC, CPMA, CCS-P, CPC-P, CRHC, AAPC Fellow
    Coder

  9. #9
    Location
    Columbia, MO
    Posts
    12,572
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    So seriousy who are you listing as the rendering provider? Whose NPI number?

    Debra A. Mitchell, MSPH, CPC-H

  10. #10
    Location
    Overland Park, KS
    Posts
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    There is a medical director that is never on the premises, and in fact has never been to this clinic to see these patients. He is the medical director of another one of our clinics in another area.
    Dawson Ballard, Jr., CPC, CEMC, CPMA, CCS-P, CPC-P, CRHC, AAPC Fellow
    Coder

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