# E/m 99211



## Thumper72 (Sep 7, 2011)

Inquiring for a co-worker...I am wondering if a phlebotomist that works for the local Health Department can charge a 99211 if they are spending time counseling the patient prior to doing blood draws for HIV or Hep C, etc. Is there a specific license that can bill this code? 

Thanks for any help!!


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## LindaEV (Sep 7, 2011)

Probably not. 

What would a phlebotomist be "counseling" on? What exactly are they "evaluating and managing"? Is there a physician on site who is contracted with the payers?


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## Thumper72 (Sep 7, 2011)

There is not an MD on site, but he does over see what they do. The phlebotomist counsels on Risks, Pre counseling, Education, protecting themselves, & obtains a Social Hx. If the 99211 can not be billed, is there a code that should be used?


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## Thumper72 (Sep 13, 2011)

*Still looking for an answer*

I'm still in need of some advice on this situation. If anyone can provide some thoughts that would be great. Thanks.


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## cheermom68 (Sep 14, 2011)

*99211*

Irregardless of the whether a phlebotomist can charge 99211 and what they are documenting, if there is no physician on site, a 99211 cannot be charged because it does not meet incident to guidelines and a phlebotomist does not have an NPI to bill under.
LeeAnn


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## MnTwins29 (Sep 16, 2011)

*for 99211...*



cheermom68 said:


> Irregardless of the whether a phlebotomist can charge 99211 and what they are documenting, if there is no physician on site, a 99211 cannot be charged because it does not meet incident to guidelines and a phlebotomist does not have an NPI to bill under.
> LeeAnn



The physician does not have to be present to bill the 99211.  However, given some of the other information in the original question, such as the various conditions for which the phlebotomist is providing counseling, I question whether this is a "minimal" problem and only 5 minutes or so is being spent with these patients.   I have reservations about using this code for these encounters.


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## cheermom68 (Sep 16, 2011)

*99211*

A physician* does* have to be present in the office suite to bill "incident to" and this is the only way that a 99211 can be billed for this encounter.  Phlebotomists are not issued NPI's to bill under. Coumadin clinics have gotten caught on this one, billing a 99211 when no physician was on site.  If a nurse, MA, phlebotomist etc is performing a service (99211, etc) using a physician or NPP NPI number the physician must be onsite.  

LeeAnn


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