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Face-To-Face Visits for Reviewing Blood Work


This administrator wonders if his physician needs to be physically present in order to bill a 99212 for infertility blood work.

Question: One of my physicians wants to bill a 99212 for a patient to come into the office and have infertility blood work drawn. The nurse would bring the patient back, find out what they are here for, do any workup required and take them to the lab for a blood draw. Once the results are back in, the physician will review and in these cases, there is always contact with the patient and plan of care/RXs for treatment. The physician feels like this is above the normal review of lab results, where the nurse contacts the patient with results, phone line notification, or card mailed. There is no doubt to me that the complexity of the problem and MDM is there for a 99212 but does the patient have to have a face-to-face with a provider to bill this code or does the review and coordination of follow-up care meet the requirements?

Answer: We get questions like this a lot! The short answer is that the physician needs to see the patient, face-to-face. 99211 is the only one that works as the "nurse visit." If that weren't the case, we'd have a collection of services of escalating complexity all being "done by proxy" by the physician through the nurse. The line is drawn between levels 1 and 2.

Bill Dacey, CPC, MBA, MHA, is principal in the Dacey Group, a consulting firm dedicated to coding, billing, documentation, and compliance concerns. Dacey is a PMCC-certified instructor and has been active in physician training for more than 20 years. He can be reached at or

This article originally appeared in the June 2011 issue of Physicians Practice.

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