# 99211 and Nurse Only Clinic



## dballard2004 (Jan 14, 2010)

This is going to sound like an odd question, but my company is giving me grief on this, so I'm looking for other opinions here, please....my company recently opened a clinic that is staffed only by nurses (RNs). There is no MD, PA, or NP onsite, just an RN. The clinic is very limited in scope of course because it is only a nurse on staff. Now here is the dilemma, the nurses want to code these visits using 99211 and my company agrees with this. I say that because there is no provider at all onsite, meaning no MD, PA, or NP, these patients never establish care to this clinic, so 99211 can't be used since this code is only for established patients. I am also looking at this as "incident to" guidelines are not being met either. I'm curious to know what others say here. Am I on the right track here? Thanks.


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## LLovett (Jan 14, 2010)

I completely agree with you Dawson.

Who do they plan on billing under? I am not aware of anyone that credentials RNs as stand alone billable providers.

Incident to is not met in 2 different ways, the most obvious no doctor is even there, and the fact there is no established treatment plan throws it out as well.

Scary what people will justify in order to earn a quick dollar.

Laura, CPC, CPMA, CEMC


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## dballard2004 (Jan 14, 2010)

My thoughts exactly Laura.  Thanks.


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## mitchellde (Jan 14, 2010)

This indeed is scary.  No you may not use a 99211 because it is not a nurse visit level it is a physician level.  It is just the only level a physician is allowed to charge when some other qualified staff member is face to face with the physician carrying out physician orders froman established plan of care.   I am curious as well as to whom these visit are to be billed under.  The last time I looked a nurses liscense does not allow the nurse to assess and diagnose a patient for any condition.


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## Walker22 (Jan 14, 2010)

I agree with you and all the others on this one. No way can they bill 99211 in that situation!


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## dballard2004 (Jan 15, 2010)

Thanks everyone!


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## Chanke (Jan 15, 2010)

Is there a doc overseeing them?  Or a medical director?  Are they nurse practitioners?  Seems awfully odd if there is none of that in place....  and no way is that level acceptable if it is just a nurse......


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## dballard2004 (Jan 15, 2010)

No doc, no nothing.  Strickly RNs only.


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## mitchellde (Jan 15, 2010)

So seriousy who are you listing as the rendering provider?  Whose NPI number?


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## dballard2004 (Jan 15, 2010)

There is a medical director that is never on the premises, and in fact has never been to this clinic to see these patients.  He is the medical director of another one of our clinics in another area.


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## MnTwins29 (Jan 15, 2010)

dballard2004 said:


> This is going to sound like an odd question, but my company is giving me grief on this, so I'm looking for other opinions here, please....my company recently opened a clinic that is staffed only by nurses (RNs). There is no MD, PA, or NP onsite, just an RN. The clinic is very limited in scope of course because it is only a nurse on staff. Now here is the dilemma, the nurses want to code these visits using 99211 and my company agrees with this. I say that because there is no provider at all onsite, meaning no MD, PA, or NP, these patients never establish care to this clinic, so 99211 can't be used since this code is only for established patients. I am also looking at this as "incident to" guidelines are not being met either. I'm curious to know what others say here. Am I on the right track here? Thanks.



Stick to your guns - see my reply to you on another forum.  99211 can't be used here, and neither can "incident to" guidelines.


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## dballard2004 (Jan 15, 2010)

Thank you so very much!  I appreciate your insight!


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## mitchellde (Jan 15, 2010)

dballard2004 said:


> There is a medical director that is never on the premises, and in fact has never been to this clinic to see these patients.  He is the medical director of another one of our clinics in another area.



I think you already know this but it bears repeating.  This physician cannot be used on these claims as either the referring provider or the rendering provider.  What are they thinking!?   this is not like a home health agency where nurses can bill for their services with a physician presciption.  as they are not set up as a physician office.  They are organized and taxed in a wholly different manner with different insurance, and state requirements and other things.


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## hsmith67 (Jan 16, 2010)

*Curiosity is getting me*

Dawson,

I have to know...just exactly what types of visits/patients are these RN's seeing? Are the RN's seeing hypertensives and adjusting meds? Diabetics and titrating meds? If that's the case you have much bigger medical liability issues, bigger than what to bill. 

The other thing is - if they are simply carrying out a plan of care...who established the plan of care to begin with if no MD/NP/PA is in the building? Are they seeing an MD/PA/NP elsewhere and then referred to this RN only clinic for follow up?

Hunter Smith, an in shock CPC


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## dballard2004 (Jan 18, 2010)

The clinic is very limited in scope because it is only staffed by RNs.  They see patients for headaches and give Tylenol and monitor BP by doing BP checks.


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## mitchellde (Jan 18, 2010)

none of which can be done without a physician order and a physician on staff.  Have they checked with an attorney and been honest with him about what is going on.  My daughter is a health care attorney and she says this cannot happen.


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## AuntJoyce (Jan 18, 2010)

What is even scarier is that there are actually patient's who come in for medical care?  YIKES!!!!!


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## hsmith67 (Jan 19, 2010)

*Scary*

I'm thinking allergic reactions, tylenol and platelet disorders, if BP is not acceptable what then? Give a diuretic? If diuretic given, that could flush other meds out of their system faster and this may not be what a PCP would want (or would make adjustments in those drugs that only a provider with a DEA# can do). 

Wow, to bill or not to bill a 99211 is the least of your worries my friend.

Hunter Smith, CPC


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## mitchellde (Jan 19, 2010)

I cannot believe that the RNs would even consider this as they are well aware (or should be) of their liscense limitations.


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