Can you bill an E&M service without seeing the patient?

by Steve Adams, CMS, CPC, CPC-H, CPC-I, PCS, FCS, COA

Have you ever wondered if you could bill for an evaluation and management (E&M) service or a diagnostic test without actually providing an “in person” visit with the patient?

For example, a patient in pre-term labor is seen in the Emergency Room (ER).  The ER physician contacts you and you ask them to place the patient in observation on your service.  You receive a telephone call from labor and delivery (LD) later that day or night to inform you of the status of the patient.  You request a fetal non-stress be performed and other specific test(s) and when complete the results are telephoned back to you at your home or office.  A few hours later you discharge the patient to home and request she follow-up with you in the office tomorrow.

Now, you’ve provided a “medical service” and received information on “diagnostic tests” but in this example the E&M services was not provided in conjunction with an “in person” face-to-face encounter with the patient and you didn’t have “direct visualization” of the NST – so in fact, neither service is billable.

According to CMS IOM 100-02 chapter 15:

A service may be considered to be a physician’s service where the physician either examines the patient in person or is able to visualize some aspect of the patient’s condition without the interposition of a third person’s judgment. Direct visualization would be possible by means of x-rays, electrocardiogram and electroencephalogram tapes, tissue samples, etc.

For example, the interpretation by a physician of an actual electrocardiogram or electroencephalogram reading that has been transmitted via telephone (i.e., electronically rather than by means of a verbal description) is a covered service.

To have a billable E&M service you would have to go to the hospital and see the patient “in person.” To bill for the NST or any other imaging test, they would have to be provided to you in an electronic format, prior to interpretation, and not by means of a verbal description. 

Remember, with very few exceptions (care plan oversight, home health certification and recertifications, certain telemedicine services, etc), if you don’t provide an “in person” service or a “direct visualization” of a diagnostic test you are not permitted to bill for your professional services.


Steve Adams is a Certified Professional Coder and Senior Consultant with InGauge Healthcare Solutions.  To read more articles like this and to register for practice management tele-classes, visit

This article can be reprinted freely online, as long as the entire article and this resource box are included.


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