For a visit to be considered a Preventive exam, there has to be age and gender appropriate counseling/anticipatory risk factor reduction interventions documented, per CPT definition. Period. Without that, all you have is a problem-oriented E/M for infertility, which wouldn't warrant anything higher than a 99212. Now, what qualifies as "counseling" may be open to interpretation. Sometimes I see notes that just say "Counseled patient regarding current medications", or if they suggested a diet/exercise regimen, suggested that the patient quit smoking, or advised them to watch out for future heath issues (and it's documented, of course), then I'll give credit for it. I'd have to see evidence of a routine/annual exam, such as routine labs, and also an extensive history and exam. The "comprehensive" definition of preventive visits isn't equivalent to "Comprehensive" for sick visits, so it's difficult to quantify, but I would expect to see the usual elements, such as ascultation of heart and lungs, at least.
The physician should use caution when changing visit-types halfway through, to ensure that they meet all of the documentation requirements for the exam that they're going to bill. If an auditor reviews a chart and gets the impression that the doctor was just trying to spin a non-covered service and label it a 'well check', they will downcode it to whatever it scored, at minimum. If they decide that the doctor was intentionally aiming to deceive the insurer to collect improper payment, the doctor could be inviting a fraud investigation from the OIG.
I imagine that this doctor probably views documentation requirements as a pointless and time-consuming formality, which is unfortunate. I haven't seen the records, but I understand your position. In my experience, it's difficult to get some physicians to understand why good documentation is so important - beyond their own self-interests (re: payment). The best you can do is get the clinical coverage criteria for a routine/well woman exam from the patient's insurer (its usually on their website), and point out how your doctor's note falls short, if it eventually does. If they still want to gamble their practice over the price of an office visit, there's not much else you can do - it's their money.
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