# RN's & E&M's



## mbell411 (Feb 12, 2010)

Are there specific rules for a nurse, (RN -- not NP) performing E&M's 99211 through 99215.??     A physician is always available.  If so, do they follow the same guidelines as the physician?


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## cheermom68 (Feb 12, 2010)

*RN's*

RN's can only perform 99211, nothing higher.  If the patient is Medicare or another payor that follows CMS's "incident to" guidelines, then those guidelines must be followed to bill the 99211.


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## SCanterbury (Feb 16, 2010)

For any new patient code 99201-99205 or established patient code above 99211, RNs may obtain the ROS, PFSH, and vitals. Everything else is physician or NPP work for coding purposes, and this doesn't change based on how near the physician is.

Seth Canterbury, CPC, ACS-EM


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## jifnif (Feb 17, 2010)

Seth, 
Do you know where I can find documentation on that?  I actually need documentation that states what a PA-student can and can't document/do.  I am having trouble locating it.  Jennifer


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## SCanterbury (Feb 17, 2010)

The guidelines don't specifically mention which parts of the visit must be performed by the billing provider (physician or NPP). Instead, CMS has indicated that the work described in the guidelines should be understood as physician (or NPP) work except when specific allowance is made otherwise.

Specific allowance is made for individuals other than the billing provider to obtain and document the ROS and PFSH subcomponents of History. In the '97 guidelines, allowance is made for ancillary staff to obtain and document the vitals (with virtually all Medicare carriers allowing this when '95 guidelines are used as well).

This is mentioned in the 10/24/05 Part B News, where it says:

"The entire set of guidelines were written to identify the physician work [emphasis added] necessary to perform and document" the medical record for an E/M service, an E/M guru from CMS tells Part B News. The official says those are - as Buechner points out - ROS, PFSH and vitals.

Medicare says that medical students are allowed to obtain ROS/PFSH only, but doesn't specifically mention allied health students. The usual understanding is that they, like medical students, are also limited to the ROS and/or PFSH portions of the encounter.


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## jifnif (Feb 18, 2010)

Thank you!  I actually found this unde CMS website!


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