I am in no way an expert in this area. These are a few thoughts that I had while playing devil's advocate for this situation...
How are you justifying the documentation to meet the criteria of office codes 99211-99215? If the documentation is met, then why couldn't you bill these codes? Have you had any trouble getting these codes reimbursed from the insurance on a regular basis?
I agree with HBULLOCK that the codes 99401-99404 seem much more appropriate for the services you described. Keep in mind to make code selections based on the services provided, regardless of insurance reimbursement. Try to maximize your reimbursement, but make sure you are doing so in an ethical and legal way.
Have you considered getting pre-authorizations for these patients for these services so that you can bill 99211-99215 or 99401-99404 on a regular basis and expect reimbursement? I realize that I do not know how many patients you are providing these services to and that this could become quite time consuming. However, some insurance companies will issue pre-authorizations for a specific length of time. Example: Pre-Authorization for 99402 to be performed twice weekly for 11/01/2011-10/31/2012.
I don't know that 99401-99404 would be considered preventative medicine in the same aspect as 99381-99397 because of the code descriptions. 99381-99397 include "evaluation and management" while 99401-99404 include "counseling".
I don't know if any of this makes sense, or only caused more questions. I hope it helps in some way though!
Tracey Thompson, CPC, CPPM