Otolaryngology Coding Alert

Question:

New Mexico Subscriber

Allergy shots are a therapeutic service and thus falls under incident to services. This, therefore, falls under the incident to rules. This means that a physician or a non physician practitioner must be in the office suite when the injections are administered. You should bill the injections codes (95115 and 95117) under whatever provider is present in the office -- the physician or the non physician provider -- per Medicare rules.

Preparation of the allergen serum (95165) and allergy testing are diagnostic services. They do not fall under incident to rules, but fall under the Medicare supervisory rules for diagnostic services, which happens to look exactly like incident to services. Since the supervisory level for the diagnostic services for most of the allergy testing looks exactly like incident to level, many people get the two rules confused. So, for most of the codes, a physician or non physician practitioner must be in the office. Some of the higher risk allergy testing codes, such as 95065, (Direct nasal mucous membrane test) have a supervision level of "personal supervision," which means that the physician must be in the exam room with the patient when the testing occurs. CPT 95165, (Professional services for the supervision of preparation and provision of antigens for allergen immunotherapy; single or multiple antigens [specify number of doses]) does not require physician per the supervision guidelines from Medicare. You will find the details on the levels of required supervision in Codify (https://www.aapc.com/codes/).

As for other payers, it is dependent on their policies for billing for the supervision of diagnostic procedures and incident to services for the allergy shots. You should get all your non Medicare payer policies in writing.