Ask an Auditor Series: Tips and Best Practices for Using 99211 Part 1

Attendees of our recent webinar, An Expert's Tips and Best Practices for Using 99211, had a lot questions about the use of the 99211 code that we didn't have time to answer during the presention. As promised, here are the answers to the questions we didn't get to.

If you're interested in watching an on-demand recording of the webinar, you can do so here. Now, let's get to the questions.

Post-Webinar Q&A

Q1: The biggest question I get asked as a coder regarding 99211 is whether the physician has to be in the office. We treat 99211 similar to “incident to,” although these services are usually provided by RNs, not NPs.

A1: 99211 service is an incident to service and the billing physician (this might be an NP or PA) has to be in the office suite and immediately available.

Q2: Is it appropriate to bill 99211 to check the results of a TB test? It would seem not.

A2: There is no definitive answer to this question. Unlike services that have their own CPT code (injections, etc.) there is no code for this service. Some payers indicate billing the 99211 on the date of the read where others indicate that CPT 86580 includes checking the result. For cases with a positive reading, one can readily understand that a 99211 will likely meet the “significant and separate” criteria required for reporting an EM service with 25 modifier.

Healthicity recommends checking with payers for coverage and/or billing criteria.

• No CC
• Vitals are not medical necessary
• Recording of results is part of the long description for 86580 includes reporting findings.

AMA says you can.

Q3: Can you bill the new prolonged clinical staff service codes with code 99211?

A3: I am unaware of a circumstance that would be both minimal and prolonged.

Q4: Who is required to do the documentation? The nurse doing the procedure or the Physician that originally ordered it? Answer: Documentation should be done by the person doing the service. Question: I have a clinic that does not carry testosterone, they have multiple patient’s bring in the drug and they charge a 99211 plus the injection 96372 code. Is this acceptable to bill a 99211? Many of the patients are Medicare and gets denied frequently.

A4: Not usually. The injection code is all that should be billed.

Q5: Can 99211 can be billed for review of MRI results – patient seen by nurse initially and then provider comes in and spends 15 minutes speaking with the patient about the results. Per the nurse – the patient has a complex history so the provider reviewed that…and a plan was put together for immunology and to follow up with her ENT who performed revision surgery. She is on a chemo agent for RX.

A5: Without the actual medical record it seems that you are describing an EM service that may be coded based on the time since it appears that more than 50% was physician provided counseling. If documentation is thorough and describes the visit as it “seems” to me; this would likely be a 99213 service.

Q6: I do a pediatrics office and they do weight checks with bilirubin checks. Is a 99211 ok if the physician is consulted and feeding regimen is discussed???

Q6: Yes

Q7: Sometimes the provider sends the pt to a PharmD located in our office. Can we bill a 99211 if the PharmD speaks with the patient re their anticoagulant treatment no matter the amt of time spent?

A7: Time would not be a controlling factor. The decision would have to be made as with other ancillary staff – was the Evaluation and Management medically necessary at this visit and was it also significant and separate from the PT/INR check and Rx.

Q8: Can you charge a 99211 for a PEG tube check/cleaning if the Dr. states to return in two weeks for the check/cleaning?

A8: Yes, unless you were the placing practice and still in the global period.

Q9: Most of the discussion regarding billing 99211s today involved the word “nurse”, but one of the first slides did mention “ancillary staff”, which is how we refer to MAs where I work. If a physician ordered a patient to return in one week for a blood pressure check and an MA completed and documented that visit, would it be billable as a 99211, the same as it would be if a nurse performed the visit? There has been much debate within our team about this, so a definitive answer would be much appreciated. Is that code permitted only for nurses, or is it also allowed for MAs?

A9: I used “nurse” as shortcut language. 99211 may be submitted when ancillary staff who are permitted to provide services in their state act within those parameters under direct supervision of MD/DO/NP/PA etc. who will be submitting the charge. You would need to check with your state to understand if they restrict any services provided by an MA.

Q10: Is chief complaint required?

A10: Yes

Q11: Nurse documented 99211 visit, provider signed, Is just provider signing an indication of involvement or should the provider convey some plan of care to show involvement along with signing?

A11: Signature alone does not show a plan of care.

Q12: Can Hepatitis C virus counseling be bill as 99211

A12: Yes