Pulmonology Coding Alert

Reader Question:

Meet 'Incident-To' Criteria When Reporting 99211

Question: Our pulmonologist performed a thoracoscopy (32602 ... diagnostic; lungs and pleural space, with biopsy) on a Medicare patient. A week later the patient returned to our office and wanted the physician to change his dressing. Instead, our nurse changed the dressing, and the patient didn't see the physician. How should we code for this?

Utah Subscriber Answer: When your physician's staff performs a service, you can report the service as "incident-to" the physician's service. To qualify as an incident-to service, you have to meet the following CMS criteria:

 The patient should be established with no new problems.

 Your nurse should perform only an incidental part of the plan of care.

 Your nurse should carry out the service in a physician office setting.

 The physician must provide direct supervision and be present in the office suite during the service.

 A relationship, such as direct employee or independent contractor, needs to exist between the physician and nurse that identifies the nurse as acting under the physician's supervision.

If your practice meets these criteria, you can report the dressing service with code 99211 (Office or other outpatient visit ... established patient). Your nurse's documentation should include the office visit's details, such as the reason for the patient's visit, and what the nurse did. Also, make sure that your nurse includes the physician's name or that the physician co-signs the nurse's note and comments, as appropriate.
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