Reader Questions: Some Staff May Use New Vaccine Admin Codes

Question: When a nonphysician practitioner (NPP) who bills independently provides vaccine counseling to a child under age 8, may she use CPT 2005's new vaccine administration codes? Alternatively, if a nurse performs the service, may she bill the new codes "incident-to" an allergist?


Delaware Subscriber

Answer: You obviously noted that the new codes' descriptors specifically reference "physician counseling." The answer to whether these codes apply to NPPs and nurses is yes and no.

An NPP, such as a nurse practitioner, may report the new pediatric-specific immunization administration (PSIA) codes if state licensure regulations consider the services within her scope of practice.

On the other hand, a nurse shouldn't bill 90465-90468 (Immunization administration under 8 years of age ... when the physician counsels the patient/family ...) incident-to an on-duty allergist. Just as nurses cannot report the higher-level office visit codes (99212-99215, Office or other outpatient visit for the evaluation and management of an established patient ...) incident-to a physician, they cannot report the new PSIA codes incident-to a physician.

The new codes' descriptors specifically require that physicians perform the vaccine counseling. Nurses, unlike NPPs, are not considered "advanced practice nurses." Therefore, CPT and state licensure scope-of-practice regulations determine which services they may report.