Orthopedic Coding Alert

If you're billing 99211 for injections, you may be coding incorrectly

How much do you really know about when to report 99211? Take the following short quiz, and then look at the box below to check your answers against those that our coding experts provided. Questions 1. Which members of a practice's medical staff can 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)?

2. Should you use 99211 if you provide a service that has its own CPT code?

3. Can practices report 99211 for prescription refills?

4. When a patient comes in for an injection, can you bill 99211?


Answers 1. Many coders don't realize that they can bill 99211 to report services that clinical staff other than the nurse provides, says Marvel Hammer, RN, CPC, CHCO, owner of MJH Consulting in Denver.

Any qualified "auxiliary personnel" who are employees of the physician (such as medical assistants, licensed practical nurses, technicians and other aides) and are working under the physician's direct supervision can provide services to patients under the incident-to umbrella using 99211. These clinicians can report 99211 as long as the patient visit meets the medical-necessity requirement for billing an E/M code. Use Incident-to Rules With 99211 "Even though an NP, PA or even an MD/DO potentially can bill 99211, the bigger question should be why would one of these providers be providing the service to bill 99211," Hammer says. "This may not be a very efficient use of their time." If your physician's documentation frequently supports billing 99211, he may need to work on improving his documentation, she says.

The physician must be present in the office space, and the auxiliary personnel must be qualified to perform the service. Because your practice reports 99211 as an incident- to service, "the nurse would have to be monitoring a problem that the physician already evaluated," because you cannot bill incident-to if the nurse evaluates a new problem, says Malea Ivey, RHIT, coder at the Orthopedic and Neurosurgical Center of the Cascades in Bend, Ore.

Although CPT does not bar physicians from using 99211, they normally use higher-level E/M codes in most cases because of the greater complexity of care they usually provide. Don't Assign 99211 as a Cure-All 2. If CPT assigns a code to the service that you perform, you should bill that code, not the nurse's code. For example, a patient comes to the office for a urinalysis and complete blood count the day before her scheduled surgery.

In this case, you should use 81002 (Urinalysis, by dipstick or tablet reagent for bilirubin, glucose, hemoglobin, ketones, leukocytes, nitrite, pH, protein, specific gravity, urobilinogen, any number of these [...]