Oncology & Hematology Coding Alert

Question: There's a note under CPT 96372 that says if there's not direct physician supervision, you should report 99211 instead. But to bill incident-to, doesn't 99211 require direct physician supervision?

Answer: You're correct that under Medicare's incident-to rules, you need direct physician supervision to report 99211 (Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician. Usually the presenting problem[s] are minimal. Typically, 5 minutes are spent performing or supervising these services).

Direct supervision means that the physician is in the office suite and immediately available to assist if needed. The physician doesn't have to be in the actual room, though.

What this means: For Medicare (and those payers with the same rules), you won't be able to charge 99211 or 96372 (Therapeutic, prophylactic, or diagnostic injection [specify substance or drug]; subcutaneous or intramuscular) for injections without direct supervision. You'll have to accept this as a non-covered service.

Support: Medicare Claims Processing Manual, section 30.5.C, states that CPT's guideline to report 99211 for injections without direct supervision "does not apply to Medicare patients." Although the CMS manual references CPT 2006 and the injection code in effect at that time (90772), you should heed the instruction that, "If the RN, LPN or other auxiliary personnel furnishes the injection in the office and the physician is not present in the office to meet the supervision requirement, which is one of the requirements for coverage of an incident to service, then the injection is not covered. The physician would also not report 99211 as this would not be covered as an incident to service."

You can access CMS's online manuals at www.cms.gov/Manuals/IOM/list.asp.