EM Coding Alert

Question: Can a nurse practitioner (NP) perform an initial comprehensive visit for a skilled nursing facility (SNF) patient?

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Answer: No, a physician must perform the initial comprehensive visit at an SNF when using the following evaluation and management (E/M) nursing facility care codes, which, regardless of the length of stay, may be used once per admission, per physician or qualified healthcare professional (QHP):

• 99304 (Initial nursing facility care, per day, for the evaluation and management of a patient, which requires a medically appropriate history and/or examination and straightforward or low level of medical decision making. When using total time on the date of the encounter for code selection, 25 minutes must be met or exceeded.)
• 99305 (… 35 minutes must be met or exceeded.)
• 99306 ( … 50 minutes must be met or exceeded.)

It may be confusing, because NPs and other QHPs may be able to perform initial comprehensive visits at nursing facilities, depending on the respective state or local laws; SNFs, however, require physicians.

The 2026 CPT^® code book says: “… visit performed by the principal physician or other qualified health care professional. Skilled nursing facility initial comprehensive visits must be performed by a physician. Qualified health care professionals may report initial comprehensive nursing facility visits for nursing facility level of care patients, if allowed by state law or regulation.”

Rachel Dorrell, MA, MS, CPC-A, CPPM, Production Editor, AAPC