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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Original Message:
Sent: 03-25-2025 14:32
From: Faith Jones
Subject: Nurse Billing
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
Original Message:
Sent: 03-24-2025 09:18
From: Leslie McDowell
Subject: Nurse Billing
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
Original Message:
Sent: 03-21-2025 16:11
From: Faith Jones
Subject: Nurse Billing
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
Original Message:
Sent: 03-17-2025 14:15
From: Avion Cummings
Subject: Nurse Billing
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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