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  • 1.  Nurse Billing

    Posted 03-17-2025 14:15

    Hi everyone 

    I'm a nurse manager at Charles River Community Health and Waltham, Massachusetts. I'm looking for any materials that I can use to teach my nurses, how to bill for visits and what criteria they need. Is there any chance anyone already has this workflow or advice on how to create it? 

    Thank you! 

    Avion 



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    Avion Cummings
    Nurse Manager
    New MA
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  • 2.  RE: Nurse Billing

    Posted 03-18-2025 06:32

    For my areas of practice, it depends on what the patient is being seen for. If it is a medication administration (allergy injection or depo) the order set already bills the medication and administration and we do not add a 99211 CPT unless the patient requires additional teaching or care beyond what is already captured in the order set. If the patient comes in and is sick or unable to receive what they came for, but does not need to see the provider, we can flip the visit to a 99211. We are also looking at other visits, such as weight checks, suture/staple removal, other visits where maybe the skill or action is not captured in the bill, so we need to capture the nurse's time. I looked at some older posts and this topic has come up a few times and has some good responses you may want to search if you haven't yet. I did not see any workflows posted.



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    Kristyn Moss BSN, RN, CPN
    Clinical Nurse Educator
    Nemours Children's Health
    West Chester PA
    302-287-3387
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  • 3.  RE: Nurse Billing

    Posted 03-21-2025 16:12

    There are a variety of codes that can be billed for under the provider that are considered incident to when performed by Auxiliary personnel which RNs are.  Most of them do require direct supervision and this year in the final rules virtual supervision was approved for direct supervision - this was a stand that AAACN Board advocated for and posted comments in the public comment period of CMS based on the suggestions of the AAACN Advocacy Committee.   I am happy to answer any specific questions if you have some but in short - in addition to billing for all 8 of the various care management services (which are under general supervision) RNs can also provide the following services that can be billed under the provider - Annual Wellness Visit, Advance Care Planning Visit, Caregiver Training Services, and Level 1 E&M codes for established patients (99211).  I uploaded some of the codes and definitions.  



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    Faith Jones MSN RN NEA-BC
    Director of Care Coorination and Lean Consulting
    HealthTech
    Powell WY
    (307) 272-2207
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  • 4.  RE: Nurse Billing

    Posted 03-24-2025 09:18

    Coding is always such a hot topic in this threads. I would again ask that AAACN consider having a coding consultant expert for this organization.

    Given the language in the MLN reference on Advance Care Planning (linked below), it does not appear that RNs can bill under the provider for this service.

    It specifically names what is meant by 'Qualified Health Professional' for coding purposes and RNs (who are not APRNs) are not included.

    https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/downloads/advancecareplanning.pdf



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    Leslie McDowell ANP-BC DNP RN
    Northwest AHEC/Wake Forest Univ Sch of Med
    Winston Salem NC
    (336) 972-7852
    ANP-BC DNP RN
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  • 5.  RE: Nurse Billing

    Posted 03-25-2025 14:32

    In the FAQs around ACP - they answer that other staff and incident to applies so it can be done as a team based approach and billed under the provider - here is their answer:

    4. Who can perform ACP services?
    As we said in the CY 2016 FPS final rule (80 Fed. Reg. 70956), the services described by CPT
    codes 99497 and 99498 are appropriately provided by physicians or using a team-based approach
    provided by physicians, nonphysician practitioners (NPPs) and other staff under the order and
    medical management of the beneficiary's treating physician. The CPT code descriptors describe
    the services as furnished by physicians or other qualified health professionals, which for
    Medicare purposes is consistent with allowing these codes to be billed by the physicians and
    NPPs whose scope of practice and Medicare benefit category include the services described by
    the CPT codes and who are authorized to independently bill Medicare for those services.
    Therefore, only these practitioners may report CPT codes 99497 or 99498. The ACP services
    described by these codes are primarily the provenance of patients and physicians; accordingly we
    expect the billing physician or NPP to manage, participate and meaningfully contribute to the
    provision of the services in addition to providing a minimum of direct supervision. The usual
    PFS payment rules regarding ''incident to'' services apply, so that when the services are
    furnished incident to the billing physician or practitioner all applicable state law and scope of
    practice requirements must be met and there must be a minimum of direct supervision in addition
    to other incident to rules. 

    And here is the link

    https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/Downloads/FAQ-Advance-Care-Planning.pdf



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    Faith Jones MSN RN NEA-BC
    Director of Care Coorination and Lean Consulting
    HealthTech
    Powell WY
    (307) 272-2207
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  • 6.  RE: Nurse Billing

    Posted 03-26-2025 09:58

    Thank you for providing that additional information.

    It prompted me to seek out what is the source of truth since the language in the MLN newsletter and above FAQs from 2016 did not seem to be aligned. 

    A colleague who is a Certified Professional Coder led me to the Medicare Coverage Database. https://www.cms.gov/medicare-coverage-database/view/article.aspx?articleid=58664

    Will say again, that the AAACN would be well served to have a certified coding professional liaison for the organization.



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    Leslie McDowell ANP-BC DNP RN
    Northwest AHEC/Wake Forest Univ Sch of Med
    Winston Salem NC
    (336) 972-7852
    ANP-BC DNP RN
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  • 7.  RE: Nurse Billing

    Posted 03-24-2025 16:38

    Wow thank you Faith for sharing these Care Coordination codes and for highlighting that with your advocacy, we were able to state the need for Virtual supervision clearly in the Physician Fee Comments.  I sure appreciate your expertise in Care Coordination and Chronic Care Management, both of which Nurses are the best person to oversee this.  Attached link is an updated fact sheet for 2025 CMS Physician Fee Schedule Rules

    https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2025-medicare-physician-fee-schedule-final-rule



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    Leondra Weiss MN, ARNP, FNP-BC, AMB-BC, C-EFM
    Clinical Nurse Educator, Family Medicine ARNP
    Harborview Medical Center, Sea Mar
    Vashon WA
    (425) 870-0558
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