You will probably get a lot of other opinions on this issue, however I will tell you that for an established patient you only need to meet 2 of the 3 components to qualify for that level - the guidelines do not specify that one of those components must be the MDM. Therefore, yes you can code a 99215 based on just the History and the Exam. There are times when this is approriate. However, if your provider is consistently doing higher level exams for lower MDMs, I would suggest that you make sure that he is documentating appropriatley to the medical necessity and not to purposely upcode.
I know others may try and dispute this based on the statement that the MDM is the over-arching decision for a level, yada yada - but I offer this information based on what we were advised by our Medicare carrier, Highmark Medicare Services. We have also had come charts reviewed for CERT that were billed as 99214 and they were actually corrected to 99215 using this criteria and we were paid the additional fees!!
Hope this helps you in some way!
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