# medicare annual wellness visits



## csmelville (Mar 15, 2016)

Is it acceptable and/or appropriate to have an RN complete 98% of an medicare annual wellness exam and just have the provider step in the room for a moment and sign the visit?

Is it acceptable and/or appropriate to bill 99215 for a medicare patient's physical exam and perform annually in addition to the annual wellness exam because medicare no longer covers 99391-99395 codes?


----------



## ValerieBatesHoffCPCCPMA (Mar 15, 2016)

*Scribe?*

The Joint Commission defines a medical scribe as an unlicensed individual hired to enter information into the electronic health record (EHR) or chart at the direction of a physician or licensed independent practitioner. A scribe can be found in multiple settings including physician practices, hospitals, emergency departments, long-term care facilities, long-term acute care hospitals, public health clinics, and ambulatory care centers. They can be employed by a healthcare organization, physician, licensed independent practitioner, or work as a contracted service.

The role of a scribe is dependent upon the provider practice and setting. It is possible for a provider to select a clinical assistant (non-licensed clinical staff) who has performed clinical duties and worked with the provider to perform scribe services. It is not recommended, however, to allow an individual to fill the role of scribe and clinical assistant simultaneously during the same encounter. This practice raises legal and other issues regarding job role and responsibilities.

http://library.ahima.org/xpedio/groups/public/documents/ahima/bok1_049807.hcsp?dDocName=bok1_049807


----------



## ValerieBatesHoffCPCCPMA (Mar 15, 2016)

*CMS PREVENTIVE SERVICES CHART - Annual Wellness Visit (AWV) PAGE 2*

CMS PREVENTIVE SERVICES CHART - Annual Wellness Visit (AWV) PAGE 2

G0438 – Initial visit
G0439 – Subsequent visit

• Once in a lifetime for G0438
(first AWV); or
• Annually for G0439
(subsequent AWV)

https://www.cms.gov/Medicare/Preven...wnloads/MPS-QuickReferenceChart-1TextOnly.pdf


----------



## Cynthia Hughes (Mar 17, 2016)

*RN performing AWV*



csmelville said:


> Is it acceptable and/or appropriate to have an RN complete 98% of an medicare annual wellness exam and just have the provider step in the room for a moment and sign the visit?
> 
> Is it acceptable and/or appropriate to bill 99215 for a medicare patient's physical exam and perform annually in addition to the annual wellness exam because medicare no longer covers 99391-99395 codes?



Yes if the work of the AWV performed by the RN is within the RN scope of license (likely since there is no diagnostic work) and the physician is available in the office suite. The Medicare policy includes a medical professional (including a health educator, registered dietitian, or nutrition professional or other licensed practitioner) or a team of such medical professionals, working under the direct supervision (as defined in CFR 410.32(b)(3)(ii)) of a physician. There is probably a direct answer to this question on the CMS site as well but see question 6 at ttps://www.noridianmedicare.com/provider/updates/docs/IPPE_and_AWV_workshop_QA.pdf

No it is not acceptable to bill a physical exam as a 99215 or any problem-oriented service. Medicare never covered routine physicals. Preventive services as described by 99381-99397 can be provided and billed to the patient when provided in conjunction with an AWV but the charge would be reduced by the overlapping elements. If the physician is addressing the patient's health issues in addition to an AWV then the appropriate level of E/M for the medically necessary services is reported based on key components that do not overlap with the AWV components (eg, PFSH).

I hope this is helpful.


----------



## csmelville (Mar 18, 2016)

Cynthia Hughes said:


> Yes if the work of the AWV performed by the RN is within the RN scope of license (likely since there is no diagnostic work) and the physician is available in the office suite. The Medicare policy includes a medical professional (including a health educator, registered dietitian, or nutrition professional or other licensed practitioner) or a team of such medical professionals, working under the direct supervision (as defined in CFR 410.32(b)(3)(ii)) of a physician. There is probably a direct answer to this question on the CMS site as well but see question 6 at ttps://www.noridianmedicare.com/provider/updates/docs/IPPE_and_AWV_workshop_QA.pdf
> 
> No it is not acceptable to bill a physical exam as a 99215 or any problem-oriented service. Medicare never covered routine physicals. Preventive services as described by 99381-99397 can be provided and billed to the patient when provided in conjunction with an AWV but the charge would be reduced by the overlapping elements. If the physician is addressing the patient's health issues in addition to an AWV then the appropriate level of E/M for the medically necessary services is reported based on key components that do not overlap with the AWV components (eg, PFSH).
> 
> I hope this is helpful.



Thank you...

How do you recommend I address the issue with a provider who knows that there are numerous providers in our area billing a medicare physical exam as a 99215 and feels justified per the patients medical needs to perform a head to toe physical exam annually on all medicare patients using a 99215?  Sometimes the CPE is in conjunction with a chronic care visit ie justifying in the providers mind billing a 99215 but it is done so often on Medicare patients that there is no doubt the main purpose of the visit is a complete physical exam.  I feel this is being done with good intentions but just does not feel right per the guidelines I am aware of.  It is a fine line as the provider is the owner of the practice and is not open to change this practice.  My recommendation was to perform AWV and recommend any preventative services needed and schedule accordingly and bill for the covered preventative services as per Medicare and if patient requests a complete head to toe CPE they sign an ABN and are responsible for the charge.  My provider does not feel this is fair to patients..


----------



## valleycoder (Mar 22, 2016)

Agree with Cynthia's answer.  99215 is for sick visits, not preventative, as you well know.  Your recommendations are spot on.  Keep preaching.


----------

