# 99211 when patient left before being seen by provider



## karlam (Apr 6, 2018)

I work in an urgent care/primary care setting. We have standing triage orders based off complaints so x-rays and labs are ordered by an MA (usually) before the providers see patients. Sometimes the patients leave after having x-rays or labs but before the providers seen the patient. I am under the impression you cannot bill an E&M for these visits but others say to go with a 99211. We don't bill "incident to" really. Our claims are filed under the extenders' names and numbers with the supervising provider as the co-signer.

Is the 99211 appropriate? Where can I find the supporting documentation?

Thanks!!!!!


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## thomas7331 (Apr 6, 2018)

If you're billing for a service performed by auxiliary personnel and not performed personally by the provider, then by definition, you are billing 'incident to'.  And if the patients have left before the provider has evaluated them for the presenting problem, then the 'incident to' requirements have not been met and services can't be billed, at least under CMS rules.   

NGS has an excellent job aid with a checklist for what requirements have to be met to bill 99211 - you can find it here (you can access by 'continue as a guest' if you don't have a log in):  

https://www.ngsmedicare.com/ngs/por.../?clearcookie=&savecookie=&REGION=&LOB=Part B

Note that is states that to bill this code the _"patient must be seen for a problem that has already been diagnosed with a treatment plan established by the physician/ nonphysician provider."_

You can also refer to this CMS publication, link below, for a summary of the 'incident to' rules.  Note here on page 1 and 2 that _"to qualify as “incident to,” services must be part of your patient’s normal course of treatment, during which a physician personally performed an initial service and remains actively involved in the course of treatment."_

https://www.cms.gov/Outreach-and-Ed...k-MLN/MLNMattersArticles/downloads/se0441.pdf

These rules aside though, I'd add that, from my personal experience, if your patient has left before seeing a provider, they're usually already very unhappy with your practice, and if you bill for services, whether it's to them or their insurance, it's like throwing fuel on a fire and a sure way to generate complaints.  It's not a good business practice, and dealing with the complaints can likely cost the practice more than the small amount of reimbursement you might get for it.


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## mitchellde (Apr 6, 2018)

No you cannot charge a 99211 unless the service is ordered by the provider based on a previous encounter.  Standing orders do not count.  You may want to check the legality of standing orders in your state.  Here you cannot use standing orders unless it is life or death and there is no provider immediately available and then only for basic lifesaving measures.  An MA should never be ordering labs and diagnostic services based on a presenting complaint without a provider having first examined the patient and determined the appropriate testing.  So you should not be charging for these services either as a provider did not examine the patient prior to having the test ordered and performed.


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