We're specifically using registered nurses who have already been implementing a chronic care management program (now we can get paid for some of their work!!).
However the level of "license" is not clarified. I would interpret this to mean that the employee under physician supervision who provides the non-face-to-face service have to hold some sort of clincial license or certification: LNA, CNA, MA, LPN, RN or BSN, and be practicing within the scope of their licensure. The decision as to whether the licensed staff is qualified to provide the care would be up to the provider, since they are responsible for the overall patient care and documentation of the work being done. This would elminiate any work done by non-clinical certified staff (such as coders) or any non-certified staff, such as practice managers or billers or non-certified MAs.
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