March 21, 2007

Dear JCAAI Member:

We recently surveyed JCAAI members regarding reimbursement for an E&M service on the same day as a skin test or on the same day as an injection (95115 – 95117). Well over 80% are paid for an E&M service on the same day as a skin test. Far fewer are paid for an E&M service on the same day as an injection. In particular, the majority of allergists reported that they were not paid for an injection on the same day they billed a minimal office visit (99211).

Under Medicare policy, neither the injections codes nor the skin testing codes have global periods. Codes that have global periods (typically procedure codes) usually cannot be billed with an office visit because the E & M service is considered bundled into the procedure. Codes that do not have global periods do not include any bundling of E & M services; thus, coding policy generally permits them to be billed on the same day as an E & M without the use of modifier-25. However, as our survey results indicate, not all payers are aware of or are following this policy. This may be because, until January 1, 2006, the injection codes were classified as global period codes (which meant that they could not be billed with an E & M service without the use of modifier-25). JCAAI was successful in getting Medicare to change this so that you are allowed to bill an E & M service (including 99211) with allergy injection codes without meeting the requirements for modifier-25. The primary reason for this change was to allow a physician to bill 99211 when dealing with clinical issues surrounding allergy injection administration (e.g., directing a nurse giving injections as to what the nurse should do if...