Here's the trick: counseling must be done when the vaccine is being administered!
Our physicians are billing for the counseling and simply state "counseling by physician" in the progress notes. I don't think anything specific has to be documented just that counseling was done by the physcian - not the nurse. We haven't had any problems. We've had insurances ask for records to verify and have had no problems whatsoever. And even better, the reimbursement for those code sets are great!! We're getting about 25 bucks a pop.
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