Coding to Get Paid Enough for Wellness Visits

Betsy Nicoletti, MS


February 21, 2019

In This Article

The Coding Expert Answers Physician Questions

Editor's Note: Betsy Nicoletti, MS, a nationally recognized coding expert, will take your coding questions via email and provide guidance on how to code properly to maximize reimbursement. Have a question about coding? Send it here.

In this column, Nicoletti addresses two follow-up questions from last month about billing correctly for same-day services.

Selecting the Right Level of Service for Wellness Visits

Question: When billing for a problem visit on the day of a wellness visit, you noted that I can't use documentation from the wellness visit to count toward the problem visit. Since there isn't a review of systems (ROS) or physical required for a wellness visit, can I count ROS or exam into the documentation when selecting the level of service for an established patient visit?

Answer: Yes. Medicare says, "Some of the components of a medically necessary evaluation and management (E/M) service (e.g., a portion of history or physical exam portion) may have been part of the [wellness visits] and should not be included when determining the most appropriate level of E/M service to be billed for the medically necessary, separately identifiable, E/M service."[1]

According to the Centers for Medicare & Medicaid Services (CMS), the ROS is "an inventory of body systems obtained through a series of questions seeking to identify signs and/or symptoms which the patient may be experiencing or has experienced."[2] CMS recognizes the following organ systems for ROS: constitutional; eyes, ears/nose/mouth/throat; cardiovascular; respiratory; gastrointestinal; genitourinary; musculoskeletal; integumentary (skin and/or breast); neurologic; psychiatric; endocrine; hematologic/lymphatic; allergic; and immunologic.

An ROS is not a required component of a wellness visit, and the only requirement for an exam is vital signs. Past medical, family, or social history are required and may not be included in selecting a level of service.

Registered Nurses and Annual Wellness Visits

Question: Can the registered nurses at my practice perform Medicare Annual Wellness Visits (AWV)? If so, is it considered a 99215?

Answer: Let me quote Medicare to answer this question:

"Medicare Part B covers an AWV if performed by a:

  • Physician (a doctor of medicine or osteopathy);

  • Qualified non-physician practitioner (a physician assistant, nurse practitioner, or certified clinical nurse specialist); or

  • Medical professional (including a health educator, registered dietitian, nutrition professional, or other licensed practitioner), or a team of medical professionals directly supervised by a physician (doctor of medicine or osteopathy)."[3]

CMS does not specifically say that a registered nurse can or cannot do the service. Some practices have interpreted this CMS guidance to mean that a registered nurse can do the service, and some have not.

I would caution against billing a 99215 in addition to the wellness visit. You cannot credit the past medical, family, or social history, so you would not have a comprehensive history. You may have a comprehensive exam, but the likelihood that the medical decision-making would be high on all of these patients is very low.


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