# Billing 99211 for subsequent wound care sessions



## teresa_bondoc@yahoo.com (Jul 19, 2018)

Before anything else, THANK YOU for your kind attention & hopefully you could respond to my dilemma.

According to the CPT manual, a 99211 is an office or other outpatient visit “that may not require the presence of a physician. Usually, the presenting problem(s) are minimal. Typically, five minutes are spent performing or supervising these services.” Unlike the rest of the office visit codes, 99211 does not have any documentation requirements for the history, physical exam or complexity of medical decision making. The nature of the presenting problem need be only “minimal,” such as monthly B-12 injections, suture removal, dressing changes, allergy injections with observation by a nurse, and peak flow meter instruction. (For more examples, see Appendix D of the CPT manual.)

Scenario. In our outpatient hospital wound care setting, the subsequent wound care sessions consist of wound care dressing changes by the RN usually 20 sq cm area of wound, ankle brachial pressure index readings by the RN for 15 minutes, and a referral back to the surgeon for his advice/opinion on the case.  The surgeon (MD) signs off on the clinical documentation of the encounter. The entire session lasts no less than 25 minutes, and on average 30 minutes. Will still be considered a 99211 billing?

Please advise.

Thank you again.


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## NiteshlalKoyalkar (Jul 19, 2018)

hi,
this looks like a postop visit, post op visit is included in the major procedures. 
if this is not a post op even then this is not reportable as the provider (md ) has signed without being face to face.


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## thomas7331 (Jul 20, 2018)

NiteshlalKoyalkar said:


> hi,
> this looks like a postop visit, post op visit is included in the major procedures.
> if this is not a post op even then this is not reportable as the provider (md ) has signed without being face to face.



This response is incorrect - a face-to-face service by the provider is not a requirement for 99211 as long as 'incident to' requirements are met.  

Although there are no specific documents requirements for 99211 as far as the E&M key components, as long as some E&M service is performed, 99211 can be billed.  In this scenario, it seems clear to me that the nurse is indeed performing an E&M service and I believe there should be no problem with billing a 99211 as long as the other requirements are met (e.g. direct supervision by the provider, the patient is established, the service is one that has been ordered by the provider as integral to the care plan).  

If the wound clinic in question is an on-campus hospital clinic, or an off-campus clinic that is eligible for provider-based billing, then this should be billed as a facility charge only (G0463 for Medicare; 99211 or other appropriate code per payer policy for payers that do not accept the G code - facilities may bill charges based on resource utilization and not on E&M key components, so the level may vary on this claim).  'Incident to' billing under the physicians credentials to Part B is not permitted in a facility setting, so no professional claim would be submitted.  Facility services are also not subject to global surgery rules, so this can be billed whether or not the service is post-operative.  

If the clinic is freestanding and does not bill a separate facility fee, then 99211 may be billed as a professional charge under 'incident to' rules as long as it is not in a post-operative global period.  NGS Medicare publishes a very good 'Procedure Code 99211 Job Aid' that details the billing requirements that I recommend - you can find it on their web site here:  https://www.ngsmedicare.com/ngs/por.../?clearcookie=&savecookie=&LOB=Part B&REGION=


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## teresa_bondoc@yahoo.com (Jul 20, 2018)

Thank you for the responses.  These are very helpful.

Because the common scenario is a 30-minute visit, with an additional procedure of determining pulse pressures, I wasn't sure if 99211 justify all the services provided for the "wound care follow-up".  

If after presenting all the pulse pressures to the MD, and the MD orders additional procedures for diagnostic purposes, or additional medications, will this session still be considered an "incident-to" service under RN, thus still a 99211 visit?

Would really appreciate your help on this.

Thank you.


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## mjstack (Mar 22, 2019)

*re: 99211*

We have this issue for our outpatient doctor as well (I bill dr not facility). It the note actually represents a bandaging and the doctor has clearly NOT touched the patient, per note, we cannot bill for the visit since the facility pays for the nurse (who bandaged). If it is a wrap or unna boot, same thing as the doctor does not performed this procedure. In our facility the doctor does put on TCC, so I can bill when documented.


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