Chart must show training's medical necessity to make appeal worthwhile. You can challenge training denials, provided your documentation supports the education's reason. "Unfortunately, not all payers will pay for 94664," notes Gary N. Gross, MD, executive vice president of the Joint Council of Allergy, Asthma & Immunology. If practices abuse the code, probably fewer payers will pay the approximately $15 national rate (0.40 transitional nonfacility total relative value units x 38.0870 conversion factor = 15.23). Solution: To support reporting 94664, documentation should include an indication of medical necessity, Gross stresses. The physician should state in the chart's plan or treatment portion two items: that the patient requires a teaching session on the use of his MDI, discus, nebulizer, etc. why the session is needed. A statement could read, "The patient did not demonstrate the proper use of his MDI."