It is my understanding that the previously mentioned method of having the MD 
come in and "bless" the care plan is only adequate if you are coding based 
on COMPLEXITY, not time.  Meaning that for anything above the 1 or 2 lowest 
codes (99201, 99202) you need to do a pretty comprehensive physical exam and 
past medical history, as specified in the code book.  If you are coding 
based on TIME (as in amount of time spent "counseling"--as most of us do) 
then the MD must be present for the entire time billed for.  SO if the MD is 
only there "face-to-face" for 5 minutes, you really cannot bill for anything 
but perhaps a 99201 under their provider name.  They were not really the 
"provider".

If you really want to be above-board about it, you need to negotiate with 
all of the local insurance plans to recognize you as a "provider" and 
negotiate a fee schedule they are willing to pay for your lactation 
services.

I would love it if I am wrong, because we could bring in a lot more revenue. 
I have 3 LCs who cannot bill independantly because last time I asked 
(admittedly...5 years ago) local insurance plans were not interested in 
recognizing them as providers.

Kathy Leeper, MD, IBCLC
MilkWorks- Lincoln, NE

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