As you may be aware United Healthcare and its Secure Horizons product line has recently taken interest in the use of CPT code 99211 with a sudden increase in audit activity. Along with UHC, more and more payers are requesting notes in an effort to verify proper provider documentation, coding and claims payments.

Secure Horizons, and any payer, has the right to audit documentation they also have tCoding Alert: The Proper Use of CPT 99211he right to withhold payment and request refunds for improperly coded services.

99211 is a minimal level service, but it is still governed by the same billing and documentation rules that ALL E&M codes have.

As with all services billed to Medicare, code 99211 services must be reasonable and necessary for the diagnosis or treatment of an illness or injury. Unlike the other E/M CPT codes, the CPT book does not specify completion of particular levels of work for code 99211 in terms of key components or contributory factors. Also, unlike the other E/M codes, CMS did not provide documentation requirements for CPT code 99211 in the “E&M Documentation Guidelines”.

Among other reasons, code 99211 should not be used to bill Medicare/Secure Horizons:

  • For phone calls to patients.
  • Solely for the writing of prescriptions (new or refill) when no other E/M is necessary or performed.
  • For blood pressure checks when the information obtained does not lead to management of a condition or illness.
  • When drawing blood for laboratory analysis or when performing other diagnostic tests, whether or not a claim for the venipuncture or other diagnostic study test is submitted separately.
  • Routinely when administering medications, whether or not an injection (or infusion) code is submitted on the claim separately.
  • For performing diagnostic or therapeutic procedures (especially when the procedure is otherwise usually not covered/not reimbursed or payment is bundled with payment for another service), whether or not the procedure code is submitted on the claim separately.

We urge you to use 99211 and other E&M codes when the services are rendered and documented properly.

If you receive a documentation request from Medicare, Secure Horizons or any other payer please fully comply as non-compliance may initiate non-payment. If your notes are reviewed and you disagree with the results, we can help you develop a strategy to appeal the finding!

If you need assistance please call us at 303.534.0388 or email us at