Wiki Billing injections and nurse visits

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coder2533

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There has been a discussion in our office about how to properly bill injections given by a nurse. We have a multi-physician practice and patients often come in for an allergy shot, testosterone injection, B-12 injection or flu shot. In the code book it says that injections given without direct supervision cannot be reported with 96372, instead you must use 99211. I am struggling to understand what provider these things should be billed under. I feel like we cannot bill under the patient's 'normal physician' if that person is not in the office. However, the clinical staff is saying that they are able to give injections without a provider present in the office at all. What is the correct way to decide who the 'rendering physician' should be, when they are just seeing a nurse? I would love any documentation you have regarding this issue.
 
in a physician office you must always have a provider in the office to render and bill for services. If there is not direct physician supervision in the outpatient department then you can use 99211. But to bill in the physician office all services must have reported a rendering or supervising provider. The supervisor that is in the office at the time of the service would be the one you bill under, using the injection administration code. You cannot use the 99211 to bill an injection in the physician office. This is all documented in the MCM under the incident to regulation.
 
In the CPT book under 96372 it says "Do not report 96372 for injections given without direct physician or other qualified health care professiona supervision. To report, use 99211." This leads me to believe that we can bill a nurse visit for an injection without a provider present.
I completely agree that there must be a provider present, but the clinical staff is disagreeing with me. Do you have any hard evidence that this is true? I referenced the Medicare manual but they said this is not considered 'incident to' so it doesn't apply.
 
That instruction is there primarily for non physician office settings. Look at your state licensure agreement. You are licensed by the state as a physician office and as such have stated that there will always be a physician or NPP present when patient's are being attended to. Also you must bill with a provider NPI in field 24J as the rendering or supervising provider. IF a provider is not physicially on site then there is no NPI you can use for this field. Also you must always consider what would happen if the patient had a sudden reaction/seizure/attack and there is no provider in the office.
 
I don't see anywhere that it states that is only for non physician office settings. I agree with not having an NPI to bill with and the reaction part but their arguement is that since we are in a large facility, they could have the physician in the office next door be 'on call' for emergencies. They are also referring to it as a standing order, where the nurse has permission to perform the service without them present. I agree with what you are saying, I am just looking for something to use as proof for my managers.
 
standing orders do not apply to physician offices only facilities. You really need to look at licensure for physician offices they do require direct physician supervision in the physician office setting. Which means the provider must be in the physical office suite area. This is defined in the MCM. Without direct physician supervision a nurse employed by a physician cannot "practice" medicine. I am not sure why the managers are putting your nurses and patients at risk this way. ALso your nurses did learn this when they were in nursing school. If a nursing scholl in in your area then please do speak with the instuctors there.
 
99211 Nurse Visit Billing

This comes up at least once a year especially around this time of year when the flu vaccine season arrives.

Attached is a file of documentation I keep on hand just for such conversations.
 

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  • 99211.pdf
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