If you’ve ever submitted claims for 99211 — also referred to by many practices as the nurse E/M visit — then you know it requires physician supervision if a registered nurse is billing it. What may be confusing to some medical teams is what type of supervision is necessary, since Medicare maintains multiple supervision levels.
You can find a code’s supervision requirement in the Medicare Physician Fee Schedule. It will advise whether a particular CPT code requires general, direct, or personal supervision. However, it may still be confusing to determine what those mean.
Check out this primer on Medicare supervision so you can bill 99211 with ease going forward.
General Supervision
If a service requires general supervision, that means the procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. This typically means the physician will have ordered the service, but doesn’t have to be nearby when it’s performed.
For instance, if you’re billing 95805 (Multiple sleep latency or maintenance of wakefulness testing, recording, analysis and interpretation of physiological measurements of sleep during multiple trials to assess sleepiness), Medicare requires general supervision for that service.
Direct Supervision
A service requiring direct supervision means the physician (or other supervising practitioner) must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. This is the level required for all incident to services.
Because 99211 is an incident to service when billed by a registered nurse, this is the supervision level you must maintain before you’re able to bill 99211 for a nurse’s E/M visit with a patient.
Personal Supervision
Personal supervision requires the physician to be in attendance in the room during the performance of the procedure.
For instance, if you’re performing fluoroscopic guidance and reporting 77002 (Fluoroscopic guidance for needle placement (eg, biopsy, aspiration, injection, localization device) (List separately in addition to code for primary procedure)), you must maintain personal supervision.
What Happens if You Don’t Meet the Supervision Requirements?
Although Medicare and other payers are very specific about meeting the direct supervision requirements before you submit 99211, you don’t need to submit documentation demonstrating that the physician was nearby when you send in your claims for nurse visits. However, if you ever get audited or are subject to a records review, insurers will quickly identify that you didn’t meet the requirements, and will then ask for their money back.
For that reason, you must maintain documentation allowing you to demonstrate that the physician was present in the office suite and immediately available when the nurse performed the office visit. Many auditors have requested reimbursement back for nurse visits after noticing that the physician was out sick on the date of service, or even away on vacation.
Want to collect for every single nurse visit? Let expert Maya Turner CPC, CPMA, CPCO, CPC-I (AAPC Approved Instructor), guide you during her online training, CPT Code 99211: Get Paid $23 Per Patient for Nonphysician Services. Register today!
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