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May 20, 2025

Nicoletti Notes

This way for news!

Written for coders and medical professionals, Nicoletti Notes is a coding blog designed to keep you up-to-date with coding news and refreshers. Written by CodingIntel founder and coding expert Betsy Nicoletti.

CMS Finalizing Principal Illness Navigation (PIN) Services

This is information from the 2024 Physician Fee Schedule Final Rule https://public-inspection.federalregister.gov/2023-24184.pdf CMS developed four HCPCS codes for Principal Illness Navigation. This service is intended to help patients with serious conditions navigate their health care treatment. PIN services are incident-to services so may only be performed in a non-facility setting Informed consent is required-the patient must […]

Medicare Coverage for Marriage and Family Therapists and Mental Health Counselors

In the Consolidated Appropriations Act, 2023 Congress mandated that Medicare provide coverage and payment for the services of health professionals who are Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs). The effective date of coverage is January 1, 2024. And of course, these professionals must enroll in Medicare in order to provide the […]

Coding Clinic Update, 2Q, 2023

Dr. Kennedy has generously allowed me to share his summary. He emphasizes that he is paraphrasing the recent advice in the spirit of “fair use” and we are responsible (and must) read the official advice directly from the Coding Clinic in light of previous Coding Clinic advice and in the context of the official ICD-10-CM conventions and guidelines. […]

Payment Denials for Unspecified Codes

From the day coders got their first glimpse at ICD-10 codes, the question went out in the land: “Will payers deny unspecified codes?” Recently, a client told me that she was seeing an increase in denials for unspecified codes from payers and I wanted to gather more information about that. Thank you to the 140 […]

How Old is Your Oldest CPT® Book

My, how CPT® has grown Thank you to everyone who completed our mission critical survey: how old is your oldest CPT® book and how many pages is it?  Page down: a summary chart is below. First, some of you save everything. I’d love to see your office shelves. There are coders out there who have […]

Why Not Bill All 99213 Visits in an FQHC?

Why not bill all 99213 visits in an FQHC? (Hint: it’s a good way of telling everyone that they were pretty easy visits.) Practitioners who work in Federally Qualified Health Centers (FQHCs) can get in the habit of billing all level three office visits, understanding that an FQHC is paid under the Prospective Payment System […]

Medicare “Audio-Only” Telehealth Services

This post discusses Medicare changes at the START of the PHE.  It is for HISTORICAL REFERENCE ONLY.  Some codes in this post have since been deleted.  This note added 2/11/2025 CMS issued multiple waivers and two interim final rules to support health care organizations and patients during the public health emergency in spring 2020 Medicare […]

Coding Telehealth Visits: Place of Service

**Just a reminder, as of Jan 1, 2025 telehealth for Medicare is extended until March 31, 2025. Congress needs to act by then. Coding telehealth visits changes faster than the weather here in New England. The resources on the site relate to Medicare policy and CPT codes and rules. Unfortunately, they don’t address individual commercial […]

Telecoding for Telemedicine

Some coders were already working from home either full time or a few days a week. Many practices and health care facilities implemented remote coding prior to the public health emergency. Now, more of you are. I call it: Telecoding for Telemedicine When we look back on this period, on our personal and professional lives, […]

Modifier CS: Cost Sharing for COVID-19 Testing and Visits Related to Testing

This post discusses Medicare changes at the START of the PHE.  It is for HISTORICAL REFERENCE ONLY. Effective retroactively to 3/18/20, there is no cost sharing allowed for COVID-19 testing or for the evaluation visits related to the testing Medicare instructs us to use modifier CS on the visits and tests, and to contact your […]

Payment for Telephone Calls During the PHE: CMS Rules for Phone Calls

Telephone codes 99441–99443 were deleted from the 2025 CPT book. This post discusses Medicare changes at the START of the PHE.  It is for HISTORICAL REFERENCE ONLY.  Some codes in this post have since been deleted.  This note added 2/17/2025   CMS rules for phone calls has changed during the course of the pandemic.  Prior to […]

CMS Update on Medical Record Documentation for E/M Services

The world as we knew it Both the 1995 and 1997 evaluation and management (E/M) documentation guidelines stated that ancillary staff could record a review of systems (ROS), and past medical, family, and social history (PFSH) in a patient record. The billing physician/NP/PA needed to document that that information had been reviewed and verified. Only […]

New Versus established Patient Visits

There are other articles on CodingIntel about the difference between new and established patients, and the rules haven’t changed, but that doesn’t mean it is always clear. Medicare definition “Interpret the phrase “new patient” to mean a patient who has not received any professional services, i.e., E/M service or other face-to-face service (e.g., surgical procedure) […]

Teaching Physician Rules – Evaluation and Management Services

CMS policy update: E/M services performed under the teaching physician rules Download this teaching physician rules quick reference sheet for a summary of the rules. The CMS rules got a major update with the April 26, 2019 Transmittal 4823. A transmittal is a communication from CMS to the Medicare Administrative Contractors. It is followed by […]

Five Urban Legends About Risk-Adjusted Diagnosis Coding

Originally published on kevinmd.com When I talk to medical practices about Hierarchical Condition Category (HCCs) and risk-adjusted diagnosis coding, I receive a lot of questions that point to the existence of persistent urban legends. Let’s separate fact from fiction. Don’t miss our Billing Guide on Risk-adjusted Diagnosis Coding for an in-depth look at this topic. Urban […]

Diagnosis Coding for Screening Colonoscopy

Some of you have read CodingIntel’s article on coding for screening colonoscopy.  The questions we get about that article are almost all related to diagnosis coding. The CPT®/HCPCS coding and the modifiers don’t raise many questions but clinicians, coders, and patients frequently ask about correct diagnosis coding and sequencing of those codes. We recently posed […]

HCC’s in Brief | The Difference Between CMS-HCC and HHS-HCC

Demographics and diagnoses Risk adjusted diagnosis coding is a model used to predict future health care costs based on demographics and diagnoses. It is most commonly used by Medicare to set rates for patients who are in Medicare Advantage plans. A Medicare Advantage plan is paid different amounts for the Medicare patients they cover. The […]

ICD-10 Coding for Suspected Cancer

Diagnosis coding for possible malignancy How would you feel if your primary care physician and your general surgeon told you-and told your insurance company on a claim form-that you had breast cancer, when you didn’t have breast cancer? You actually had atypical ductal hyperplasia, not breast cancer. Not only have they told you, the claim […]

Who is Responsible for Coding Physician Services?  The Medical Provider or the Coder?

Legally, when a physician, physician assistant (PA) or nurse practitioner (NP) enroll in a Medicare, Medicaid or commercial insurance, the practitioner signs an agreement attesting that accurate claims will be submitted. Practitioners are responsible for claims submitted under their National Provider Identifier (NPI). CMS’s E/M guide says, When billing for a patient’s visit, choose codes […]

OB Coder Survey | Billing Extra Visits During Pregnancy

Thank you to the 63 generous coders and billers who answered my questions about billing extra OB visits during the maternity period. If we and our payers are following CPT® rules, these extra visits caring for a pregnant patient are separately billable. The editorial comments at the start of the Maternity Care and Delivery section […]

What Does the Decision to Perform a Minor Procedure Really Mean?

This article is updated with CPT’s March 2023 document, “Reporting CPT Modifier 25.” (citation at the end of the article) The CPT article adds specificity to what is included in typical pre and post work, which will make it more difficult to report both a procedure and an E/M service for some encounters. According to […]

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Our mission is to provide up-to-date, simplified, citation driven resources that empower our members to gain confidence and authority in their coding role.

In 1988, CodingIntel.com founder Betsy Nicoletti started a Medical Services Organization for a rural hospital, supporting physician practice. She has been a self-employed consultant since 1998. She estimates that in the last 20 years her audience members number over 28,400 at in person events and webinars. She has had 2,500 meetings with clinical providers and reviewed over 43,000 medical notes. She knows what questions need answers and developed this resource to answer those questions.

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