E/M Visit by RN in Hospital OB Triage
When our pregnant patients come through ED, they are sent to our L&D unit to be triaged. (L&D Triage is not an extension of the ED.) Nurses usually assess the patient, call the physician and get orders to treat the patient or send her home.
Traditionally, we have posted 99211 when no other services were provided. A vendor came in and created a matrix so that nursing now posts E/M charges for 99211-99215 to account for the time and resources used not captured through other separately billable services. (The revenue code is 0720.) The visit charge may be posted in addition to observation services and inpatient admits.
I find lots of resources for nurse visits within a practice but I'm not finding any guidance when it's a nurse within an outpatient department of the hospital. Does anyone have resources for hospital nurses that they would share, please?
Thanks!
Comments
In the research that I have done in the past a visit performed by a RN was not separately billable because incident-to criteria is not met. CMS has stated that in order to achieve a "benefit category" the service must meet all incident-to guidelines as stated in the Medicare Benefit Policy Manual Chapter 6 - 20.5.1. This states, "However, during any course of treatment rendered by auxiliary personnel. the physician must personally see the patient periodically and sufficiently often to assess the course of treatment and the patient's progress and, when necessary, to change the treatment regimen. A hospital service or supply would not be considered incident-to a physician's service if the attending physician merely wrote an order for the service or supplies and referred the patient to the hospital without being involved in the management of that course of treatment." As a result of this guidance, without a patient having a face-to-face with the provider, the service is not billable.
Furthermore, in the Medicare Benefit Policy Manual Chapter 6 - 20.5.2 the following guidance is given: "Therapeutic services and supplies which hospitals provide on an outpatient basis are those services and supplies (including the use of hospital facilities and drugs and biologicals that cannot be self-administered) which are not diagnostic services, are furnished to outpatients incident-to the services of physicians and practitioners and which aid them in the treatment of patients. These services include clinic services, emergency room services, and observation services. Policies for hospital outpatient therapeutic services furnished incident-to physicians' services differ in some respects from policies that pertain to "incident-to" services furnished in office and physician-directed clinic settings."
Hospital outpatient therapeutic services and supplies must be furnished under the order of a physician or other practitioner practicing within the extent of the Act, the Code of Federal Regulations, and State law. They must be furnished by hospital personnel under the appropriate supervision or NPP as required in the Medicare Benefit Policy Manual and by 42 CFR 410.27 and 482.12.
Providers may bill Medicare fore any diagnostic services furnished to the patient but would recommend against billing nursing visits where there is no face-to-face with a provider.
While the above is true, there may be some allowances under the State Nurse Practice Act and State Law that is specific to OB nurses and what they are allowed to do. In some state, these nurses are considered specialty nurses and are recognized as such. You also want to check with your payers to see what their policies are for acknowledging/not acknowledging this triage in the OB area.