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Outpatient Facility Coding ED and Urgent Care E/M's - Nurse Only 99201

Kelly Posted Tue 10th of December, 2019 12:01:02 PM
I am asking my question from the facility perspective only. Our hospital utilizes a point system to 'earn' the facility E/M for both the Emergency Department and Urgent Care settings that measures facility resource consumption as directed by CMS. 1. Is it appropriate to report 99201 in the Emergency Department if the patient is truly considered a new patient and does not see a physician, but uses facility resources by seeing only the nurse? For example: The patient is triaged by a nurse, has an initial assessment and vitals documented. 2. Is it appropriate to report 99201 in the Urgent Care setting if the patient is truly considered a new patient and does not see a physician? For example: Patient comes in needing a PPD blood test. The nurse reviews paperwork and asks questions/educates patient on PPD results/next steps.
SuperCoder Answered Wed 11th of December, 2019 09:49:07 AM



Generally speaking, NPs are allowed a wide range of responsibilities in the ED, depending on their training and level of experience. Specific duties are regulated by state practice law, however, and each ED must determine what is appropriate. In addition, the collaborating physician (or, in the case of a physician assistant [PA], the supervising physician) and the hospital itself may limit the nature of services NPs are allowed to provide (e.g., specific types of surgical procedures). Frequently, NPs report the appropriate level of E/M services (99281-99285), as well as initial observation care (99218-99220) and observation discharge services (99217). Likewise, they may report specific, approved procedures like placement of a peripherally inserted central catheter (PICC) line (e.g., 36489, Placement of central venous catheter [subclavian, jugular, or other vein][e.g., for central venous pressure, hyperalimentation, hemodialysis, or chemotherapy]; percutaneous, over age 2).


Within this context, reimbursement will depend on the payer. Medicare places no formal restrictions on the types of care a nonphysician practitioner (NPP) can provide, although services must be reported under the NPs provider identification number. Claims will be paid at 85 percent of the physician fee schedule. Incident-to billing does not apply in a hospital setting. Medicaid policy differs from state to state.


In urgent care setting, nurse practitioner can report 99201 under the his/her NP's identification number.


Please also check below link:



Kelly Posted Thu 09th of January, 2020 23:01:54 PM
Thank you for the information, but I am aware of the scope of services NP's can provide. My questions is specific to Registered Nurses only... Please advise. Thank you.
SuperCoder Answered Fri 10th of January, 2020 07:56:58 AM



The difference between a physician assistant (PA) or nurse practitioner (NP) and a registered nurse (RN) is that the PAs and NPs have their own billing numbers. Nurses do not. Therefore, PAs can bill either using their own billing numbers or incident-to the physician's services using the physician's billing number. Therefore, Registered Nurses (RN) cannot bill these services.


Please also check below link:


Hope this helps



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