# 99211 vs 96372 - reported unless



## Anna Weaver (Mar 19, 2009)

I'm confused on this one! I have read other sources that says 99211 cannot be reported unless the physician is in the office (incident-to) 

Medicare claims processing manual states:
"The CPT 2006 includes a parenthetical remark immediately following CPT code 90772 (Therapeutic, prophylactic or diagnostic injection; (specify substance or drug); subcutaneous or intramuscular.) It states, “Do not report 90772 for injections given without direct supervision. To report, use 99211.”
This coding guideline does not apply to Medicare patients. If the RN, LPN or other auxiliary personnel furnishes the injection in the office and the physician is not present in the office to meet the supervision requirement, which is one of the requirements for coverage of an incident to service, then the injection is not covered. The physician would also not report 99211 as this would not be covered as an incident to service."

96372 cannot be reported unless the physician is in the office. So, what do you do? If neither can be reported without physician present, why even provide the service if the physician is not in office. 
Can anyone clarify for me please? Would appreciate all answers!


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## dmaec (Mar 19, 2009)

Anna, my take on this is "direct supervision" - 
Direct supervision generally means to be physically present, or within an immediate distance, such as on the same floor, and available to respond to the needs of something or someone. Precise definitions vary by context and governing entity. For eaxample, in the context of employment law, it may involve defining the degree of control over a worker's tasks. Direct supervision on a job may be defined by the degree of supervision by a person overseeing the work of other persons, by which the supervisor has control over and professional knowledge of the work being done.

so, if the physician is not in that building, not available for "supervision" then it'll be the so called "nurse visit" E/M code, along with the J-code meds. (direct supervision doesn't mean the physician has to be in the room and personally observe the injection given).  
We use the "new" code the same way we did with the old one (90772)  regarding "direct supervision".  We haven't had any issue with payment.

anybody else?.....


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## Anna Weaver (Mar 19, 2009)

*99211 vs 96372*

I guess what I'm asking is this:
If Dr is at hospital doing rounds, his office is open for nurses to provide services (B/P checks, injections, etc). How can they provide injections in the office if the physician is at the hospital when the rules state that neither the 99211 or the 96372 will be covered? 
I'm really struggling with this. Should they not do injections when the physician is elsewhere but continue with other services?


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## kbarron (Mar 19, 2009)

I feel the same way. The provider is suppose to be available if the pt has an allergic reaction to the medication. How far away is the hospital?


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## dmaec (Mar 19, 2009)

OHHH!!... I get the question now! (I see)... but I guess I was under the impression that for the 99211 E/M - it's for the evaluation and management of an established patient, *that may not require* the presence of a physician. Usually, the presenting problem(s) are minimual. Typically, 5 minutes are spent performing or surpervising these services.

I've never seen your finding of:  _"This coding guideline does not apply to Medicare patients. If the RN, LPN or other auxiliary personnel furnishes the injection in the office and the physician is not present in the office to meet the supervision requirement, which is one of the requirements for coverage of an incident to service, then the injection is not covered. The physician would also not report 99211 as this would not be covered as an incident to service."_ 
Is that guideline on CMS site, or where is it?

and if that's the case,... I question it too!  Apparently, we code non Medicare only this way then. hmmm,.....


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## cheermom68 (Mar 19, 2009)

*99211*

CPT assistant August 2008 states:
"CMS provides some direction for reporting code 99211 for visits in which only the nurse sees the patient and gives an injection.  CMS notes that it is not correct to report an E/M service if the nurse services are only related directly to the injection itself. "
"If the nurse provides the 99211 visit, it is reported under the physician's name and tax ID number, making it inherently an "incident to" service.  In such situations, it is a service restricted to established patients and requires the supervising physician's "direct supervision", which is defined by CMS as the physician being physically present in the office suite (not in the patient's room) and immediately available to provide assistance. 

This seems to state that you cannot charge the 99211 either, if the physician is not in the office suite.  Personally as an RN I would be uncomfortable giving injections, with potential side effects, without immediate assistance available.  This could be a legal issue if something happened and the physician was not available to assist.

It sounds to me like CMS, not allowing the charge for either the injection or the E/M code, is discouraging this practice, and in my opinion rightfully so.


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## Anna Weaver (Mar 20, 2009)

*99211 vs 96372*



dmaec said:


> OHHH!!... I get the question now! (I see)... but I guess I was under the impression that for the 99211 E/M - it's for the evaluation and management of an established patient, *that may not require* the presence of a physician. Usually, the presenting problem(s) are minimual. Typically, 5 minutes are spent performing or surpervising these services.
> 
> I've never seen your finding of:  _"This coding guideline does not apply to Medicare patients. If the RN, LPN or other auxiliary personnel furnishes the injection in the office and the physician is not present in the office to meet the supervision requirement, which is one of the requirements for coverage of an incident to service, then the injection is not covered. The physician would also not report 99211 as this would not be covered as an incident to service."_
> Is that guideline on CMS site, or where is it?
> ...




I found this in the medicare claims processing manual. It is section 30.5 under C the last paragraph. So, you can see my dilemma, I have been told that the nurses can charge this, then I find this medicare guideline and I'm really not sure any longer. 
I think the more I get into this the more confused I get!!!


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## Anna Weaver (Mar 20, 2009)

*99211 vs 96372*



cheermom68 said:


> CPT assistant August 2008 states:
> "CMS provides some direction for reporting code 99211 for visits in which only the nurse sees the patient and gives an injection.  CMS notes that it is not correct to report an E/M service if the nurse services are only related directly to the injection itself. "
> "If the nurse provides the 99211 visit, it is reported under the physician's name and tax ID number, making it inherently an "incident to" service.  In such situations, it is a service restricted to established patients and requires the supervising physician's "direct supervision", which is defined by CMS as the physician being physically present in the office suite (not in the patient's room) and immediately available to provide assistance.
> 
> ...



I agree with you, I would be afraid of something happening and no help available. I've taken this on to my supervisor and we'll see where we go from here.


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