Question: Can Chiropractors bill code 99211?

Answer: While technically this code could be used, in reality it would be rarely used in a chiropractic office. This code (99211) is a low complexity examination for an established patient. It can be used by chiropractors, but in most instances, it is discouraged.

Note: In 2021, this code will experience some change in requirements as part of the comprehensive E/M changes. See the 2020 ChiroCode DeskBook for more information..

The 99211 code, also known as the nurse’s code, is not really made for the physician to use. In fact, the AMA, CPT book states “may not require the presence of a physician.” In the medical setting, it might be used for a visit where the nurse just takes blood pressure, or records the patient’s response to a new medication.

Be aware that the services included with this code are considered bundled into the manipulation code; therefore, code 99211 should not be used on the same day as a Chiropractic Manipulative Treatment except when it is significant and separately identifiable.

Some practices have erroneously tried to increase reimbursement by submitting 99211 in conjunction with therapies that are supervised by non-physician personnel every time the service is performed; their rationale is that this code pays for the presence of someone other than the doctor. This is incorrect because the “practice expense” portion of the “Relative Value Unit” includes reimbursement for office overhead required to perform the therapy code; therefore, reporting 99211 may be considered a sort of “double dipping.”

If, however, a re-evaluation or assessment is performed in addition to the therapy, then an E/M code may be appropriate. Note that the criteria for reporting code 99212 are very easy to meet, and a typical periodic re-evaluation in a chiropractic office is almost always a higher complexity than that seen in code 99211 because it only requires a presenting problem that is minimal and does not require any of the three key components needed for other E/M codes. Therefore, chiropractors would very rarely use it as a re-evaluation code since a re-exam typically meets the criteria for at least a 99212.

So when can it be used? If the patient comes in for a follow-up visit and no adjustment is performed, then possibly a 99211 may be used. An example might be when a staff member pulls a chart, and an assistant gathers some sort of information from the patient and records it.

An older Palmetto Medicare document suggested that the following criteria should be met:

• A minimal presenting problem/symptom
• A relevant and necessary exchange of information between licensed personnel and the patient
• If there is no presenting problem, and no treatment is given, consider a preventive medicine code instead, such as 99401 (but the provider must perform this service).

As you can see, there are a few times you could bill code 99211, but it should be used on an occasional basis at most.