69209 Medical Assistant

Can you bill for a 69209 (removal of cerumen using irrigation/lavage) when it is performed by a Medical Assistant? The CPT changes clinical example is for a nurse but my providers feel that it should be able to be billed for when a nurse performs it.


  • edited June 2017
    I have not seen anything that Medicare says it has to be performed by a licensed person - so I don't see a problem with an M.A. doing it.

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  • 69209 is very interesting, because in my notes from 2016 CPT Symposium, the Medicare directors advised it must be a qualified healthcare professional (QHP). However, when I went to the MPFS for more direction, the PC/TC indicator is 5, meaning it's an incident to code. As directly from the MPFS RVU17B PDF, in attachment A:

    "5 = Incident To Codes - This indicator identifies codes that describe services covered incident to a physician's service when they are provided by auxiliary personnel employed by the physician and working under his or her direct personal supervision. Payment may not be made by carriers for these services when they are provided to hospital inpatients or patients in a hospital outpatient department Modifiers 26 and TC cannot be used with these codes."

    My interpretation of the MPFS PC/TC indicator being 5 is if the auxiliary staff are appropriately trained and supervised, they may perform the irrigation and the provider may bill. However, this is only my interpretation and you may want to seek specific health plan/carrier input.

    Hope this helps.


    Kris Cuddy, CPC, CIMC
    Healthcare Compliance Analyst
    Compliance Office
    Michigan State University HealthTeam
    East Lansing, MI
    Ofc: 517-355-4547
    Fax: 517-353-5292

  • edited June 2017
    I would agree.

  • edited June 2017
    I believe it has to be performed by a physician or Nurse practitioner according to the CMS guidelines.

    Pat Dobbs RN, CPC

  • edited June 2017
    What CMS guidelines?

    There are 0 work RVUs. It is fine to bill if performed by an MA.

  • edited June 2017
    Hi Pat,

    Would you please provide the reference for this from CMS?
    Thank you.

    Siu B. Chu, CPC, CPMA, CEMC
    Sr. Compliance Specialist
    New York University - School of Medicine
    Office of Internal Audit Compliance & Enterprise Risk Management
    1 Park Avenue, 3rd Floor
    New York, New York 10016
    Ph : 212 - 404 – 4083
    Fax: 646-754-5399
    E-mail: siu.chu@nyumc.org

    From: nursedobbs1@aol.com [mailto:nursedobbs1@aol.com]
    Sent: Wednesday, May 17, 2017 2:08 PM
    To: Multiple recipients of list PARTB-L
    Subject: Re: [partb-l] 69209 Medical Assistant

    I believe it has to be performed by a physician or Nurse practitioner according to the CMS guidelines.

    Pat Dobbs RN, CPC

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