I know that billing can be confusing. it is certainly not something that is taught in school or many times even part of ambulatory care nursing orientation. A couple points that I learned as an ambulatory care manager:
-scope of practice and billing are related but not the same. An activity that is clearly within the scope of practice of an RN is not always billable. For instance if a provider sees a patient for a visit on a particular day and bills for that care, the RN cannot bill a 99211 on the same day, even if significant services are provided. The billing codes assumes that all the services provided are part of the office visit and are seen as one service. There are some codes that could be billed, but not 99211. 99211 could be billed on a different day for services provided that fall under the plan of care such as chronic disease management)
-to bill for a service a patient must be established with a qualified health provider (QHP = those able to independently diagnose and treat - MDs, DOs, APRNs, PAs, CNM, etc.) and that service be part of the overall plan of care (or ordered by the provider). Billing codes presume that allied health staff are not able to diagnose, thus from a billing perspective the nurse would not be able to bill "incident to" for an acute concern that has not been diagnosed. From a scope of practice perspective, there are services that would be within the RN's scope to provide, and they could do so but would not be able to bill. 99211 is not a code exclusively used by RNs, it is the only E & M code that can be billed by non-QHPs so depending upon institutional guidelines and standards, it can be used by others who have the skills and competency to perform the service.
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Stephanie Witwer PhD RN NEA-BC FAAN
Emeritus Staff
Mayo Clinic
Pine Island MN
(701)240-6208
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Original Message:
Sent: 09-03-2022 13:34
From: Larry Garrett
Subject: Nurse Visit for UTI- Can We Bill?
Have you considered something along the lines of a co-encounter? The RN starts the encounter - following a protocol - and at the end of the encounter, they would provide a short SBAR report to the provider. The report would be given to the provider in the exam room with the patient present. Then you could bill the encounter as your billing department sees fit. The RN service would fall under the "incident to" service rules and the time requirement of the provider would be decreased. Of course, you need to check your state's Nurse Practice Act to see if you are working within the limits of the Act as the RN scope of practice varies state by state.
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Larry C. Garrett PhD, MPH, BSN
Assistant Professor - Clinical
University of Utah
College of Nursing
Salt Lake City Utah
801-367-3811[
Larry.garrett@nurs.utah.edu
Original Message:
Sent: 08-31-2022 17:57
From: Lauren Burnell
Subject: Nurse Visit for UTI- Can We Bill?
We are drafting a protocol for RNs to conduct nurse visits and treat for presumptive UTI. We would like to bill a 99211 for these visits, but have heard mixed messages on whether these visits are truly billable. Does anyone currently utilize a similar nurse visit/treatment protocol?
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Lauren Burnell
Director Ambulatory Nursing Services
Intermountain Healthcare- Peaks Region
Broomfield CO
(303) 514-1301
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