Practice Management Alert

Question: I'd like to get verification on billing for allergy testing (95004), allergen prep (95165), and allergy injections (95115 or 95117). Our nurse actually is the person doing all of these procedures and then the physician looks at the information at a separate time. Does a physician need to be present in the office at the time any of these procedures are being performed?

New Mexico Subscriber

Answer:  Allergy shots are a therapeutic service and thus fall under incident to services. This means that a physician or a higher-licensed 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. Since the supervisory level for the diagnostic services for most of the allergy testing looks exactly like the incident to supervision 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 to supervise your nurse if you're going to bill her services.

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 presence per the supervision guidelines from Medicare. You can find the details on the levels of required supervision on 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.