in 2002 Feb 11 Kathleen Mueller who was the CMS compliance officer wrote an article for Decision Health regarding the usage of the 99211. One of the things she stated was not allowed was using the 99211 to bill for a blood draw. You have a code for this activity either 36415 or 36416. Inherent in those codes are all the services required by the nurse for that blood draw.
This is no different from the physician that has an eval and performs the joint injection and orders the patient ot reurn in a week for a repeat inject. The physician on the 2nd injection cannot charge the OV and the injection he gets the injection only.
So for the blood draw encounter, the physician has evaluated the patient and has charged the E&M and has ordered the patient to return for a repeated blood draw. There is nothing more being performed that what was ordered by the physician and there is a code for the blood draw. Therefore we cannot charge the 99211.
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