99211 Q&A: Get Paid More for Your Nonphysician Staff Services

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99211 Q&A: Get Paid More for Your Nonphysician Staff Services

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You can get paid for the additional services provided by your medical assistants and registered nurses provide. The amount depends on the number of non-physician staff you employ. For a small practice, this can equal as much as $20K more per year.

To access this additional reimbursement, you must correctly utilize CPT code 99211 for your LPN and MA services. Otherwise, you are just giving their time away. To help practices just like yours access this added reimbursement, expert coder and educator Kim Huey, MJ, CHC, CPC, CCS-P, PCS, CPCO, recently presented a 60-minute online training where she walked attendees through the process step-by-step.

To help you benefit from this added reimbursement, below you’ll find several of the questions posed by attendees at the end of the Kim’s recent training, along with her recommended solutions.

PA Supervision

Q: Can a Physician Assistant (PA) be a supervising provider for MA or LPN services billed as 99211?

A: Yes, a PA can be the supervising provider when billing services with 99211.

Taking Patient Vitals

Q: Can we bill 99211 if our MA takes a patient’s vitals? 

A: Whether taking a patient’s vitals qualifies for 99211 depends why the patient came to see you in the first place. For example, if the patient comes into a Coumadin clinic for a check, you really don’t need vitals. However, if the patient comes into your practice for a blood pressure check, you probably want all the vitals. Taking vitals on its own is a qualifier for billing 99211. It all depends on whether the vitals are medically necessary for the patient’s visit.

Copay Requirements

Q: Should we charge a copay for a 99211 qualified patient visit?

A: Yes, if the patient’s insurance requires you to collect a copay for an office visit service then you are contractually obligated to do so. However, there is nothing that says you must collect the copay at the time of service (although that typically is how most practices do it). So, if you are unsure of the amount to collect for a 99211, you can always contact the payer, and then bill the patient after the fact.

Nurse Ultrasounds

Q: We are a fertility clinic, and our nurse provides a variety of services that we are not being reimbursed for. For example, our nurse does patient ultrasounds for monitoring or to set a baseline, and then provides counseling to the patient regarding next steps. She also sometimes provides the ultrasound without additional time to counsel the patient. Can any of these services be billed with 99211?

A: To be answered clearly, your question needs to be approached in two parts:

  • Ultrasound and counseling: The nurse provides both an ultrasound and counseling. This type of a visit would meet 99211 requirements, but unfortunately, most payers will not reimburse it. However, as always, it depends on the payer, so don’t write off the possibility of being paid for the additional services provided until you check.
  • Ultrasound with no additional services: Your nurse provides an ultrasound without additional counseling. In this case the visit does not meet 99211 requirements. Your nurse is not providing any additional services beyond the ultrasound. Accordingly, if your payer allow nurse-provided ultrasounds to be reimbursed, the services would be covered by submitting the appropriate ultrasound code.

Managing Prescriptions

Q: We have patients that are having trouble managing their prescription medications. Accordingly, our nurses sometimes will fill patient pillboxes with their medications. Sometimes patients drop off their pillboxes and medications and the nurse never has any face-to-face time with them. Other times, she sits down with the patient and walks them through the process. Do these services qualify for 99211 to be billed?

A: Unfortunately, if your nurse fills patient pillboxes without any face-to-face time with them, the service doesn’t qualify for a 99211. However, if the nurse has a conversation with the patient to walk them through how to correctly take their medications, this visit does qualify. Counseling patients on how to correctly take their medications is medically necessary to their care. To support your claim of a 99211 service, have your nurse document something like, “Dr. Jones discussed with the patient that he is concerned that she is not taking her medications properly and asked me to organize and coach the patient in this area. Accordingly, I reviewed all of the patient’s medications, filled her pillbox to facilitate medication compliance, and met with the patient to walk her through what she has to do and how important it is to take all medications prescribed based on the doctor’s directions.”


Q: Can we utilize 99211 for non-physician services provides via telehealth?

A: Ultimately, this will depend on the payer. Some will allow it, and some won’t. A good place to start is to look at Medicare rules as a baseline, but again, this is going to be very payer specific.

Before the Public Health Emergency (PHE), you could not bill Medicare for a 99211 via telehealth. The code descriptor clearly indicates that 99211 services must be face-to-face to qualify. However, the rules changed with the pandemic. Accordingly, as long as PHE is in place, and you meet all other 99211 requirements, Medicare should reimbursement for these services.

Newborn Weight Checks

Q: I work in a pediatric office. On occasion, our physician requires newborns to come back in a week for weight checks, and usually our CMA provides does this. With appropriate documentation, would this qualify as a 99211?

A: As with everything in coding, there isn’t an easy answer. It really depends on what occurs during the visit and the insurance the patient has. In many instances, during a newborn’s weight check, the mother will have questions and ends up meeting with the physician.  If this occurs, the visit can be billed as in E/M office visit by the physician as a 99212 or 99213 depending on what transpires.

If the mom and baby only see the CMA, your ability to bill 99211 depends on details of the visit. Typically, if the CMA takes the newborn’s weight without any detailed interaction with the mon, the visit will not qualify as a 99211. However, if the CMA weights the newborn, and proceeds to get additional information from the mother regarding the baby (i.e., how often the baby is eating, is the baby being breast or bottle fed, any problems the new mother is experiencing, etc.), and then documents the conversation, this could support billing 99211. Whether you are paid or not depends on whether the payer will allow the claim, but in this example it should qualify.

When it comes to Medicaid, every state is different. For example, Alabama Medicaid only pays for 16 office visits a year for a newborn, regardless of the services you provide. So, if you choose to use one of those 16 annual office visits as a 99211, you lose the opportunity to bill a future visit at the higher E/M rate. Accordingly, it is extremely important for you to understand the filling rules related to your state’s Medicaid program.

You can receive additional advice on how to get paid for more of the services your MAs and LPNs provide by registering for Kim Huey’s entire online training, CPT Code 99211: Get $23 Per Patient on Nonphysician Work

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