Question: Does a certified nurse specialist (CNS) count as a nurse practitioner (NP) for 99213 based on time? Florida Subscriber Answer: Yes, for CPT purposes, a CNS counts the same as an NP or physician assistant. So if the office visit meets the requirements for time-based billing --counseling and/or coordination of care comprises more than 50 percent of the face-to-face CNS-patient encounter and documentation indicates the encounter's total face-toface time, the counseling minutes, and a discussion summary, the CNS can choose the office level using time,such as 15 face-to-face minutes for 99213 (Office or other outpatient visit for the evaluation and management of an established patient -) as the sole criteria. Be careful: Check your state law. State scope of practice laws may restrict services and procedures that nonphysician practitioners may provide.