You may not bill a new patient as establish, this looks like a non billable encounter if you cannot meet even the most basic of the 99201.
The support for this is a new patient is clearly defined as one that has never been to that physician /practice. You cannot elect to bill as an established when clearly they are not. The reason the established criteria is easier to meet is that the patient has been there before and there is historical data available for the physician to review so that certain elements do not necessarily need to be repeated for good care but cannot be counted if not performed. A new patient has no such data for the physician to referr to so all element must be performed for it to be a visit.
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