Who Can Bill What?
Medicare rules breakdown for which staff roles can fulfill each billing code category. Know your "General Supervision" rules.
Billing Practitioner
The MD, DO, NP, or PA who oversees the care, initiates the care plan, and gets paid. Required for physician-specific codes and face-to-face visits.
Clinical Staff
RNs, LPNs, and CMAs who can do the actual minute-by-minute work under General Supervision. The doctor must be available (by phone) but doesn't need to be present.
What is "General Supervision"?
Provider Available
The MD/NP/PA must be available (e.g., by phone) during care delivery.
Not Same Location
Provider does NOT need to be in the same room or even the same building.
Clinical Staff Works
RN, LPN, or CMA performs the actual work while provider supervises remotely.
Code-by-Code Breakdown
994909943999487994899942699427These codes pay for 'Clinical Staff time.' The person must have a clinical license or certification.
9942499425These are specific 'Physician/NPP time' codes and CANNOT be delegated to nurses or clinical staff.
994539945499457994589897598976989779898098981994459947098979Setup codes (99453/98975) can often be done by MA, LPN, or RN. Management codes (99457/98980) require 'interactive communication' — a clinical person must speak/message with the patient about their health data.
994849949299493Requires a 'Behavioral Health Care Manager' — a specific role usually filled by LCSW, Psychologist, or Psychiatric RN with specific training in collaborative care.
G0019G0022G0023G0024These codes allow for 'Auxiliary Personnel' — broader than clinical staff. Includes CHWs, Peer Support Specialists, and Navigators, provided they are trained and certified where applicable.
9949599496Split Role: Interactive contact can be done by clinical staff (RN/LPN/MA), but the required face-to-face visit MUST be performed by MD, DO, NP, or PA. A nurse cannot perform the face-to-face visit.
G0556G0557G0558No specific 'time tracking' requirement. The MD/NP/PA accepts the capitated payment and responsibility, while care is delivered by the whole team.
Quick Reference Summary
| Code Category | Authorized Staff (Performing the minutes) |
|---|---|
| CCM / PCM (Staff Codes) | RN, LPN, MA (Clinical Staff) |
| PCM (Physician Codes) | MD, DO, NP, PA (Providers only) |
| RPM / RTM | RN, LPN, MA (Clinical Staff) |
| BHI (General) | RN, LPN, MA, LCSW |
| CoCM (Psychiatric) | Behavioral Health Care Manager, LCSW, Psych RN |
| CHI / PIN (Navigation) | Community Health Workers, Navigators (Auxiliary) |
| TCM (Face-to-Face) | MD, DO, NP, PA (Providers only) |
| APCM | Whole Team (bundled payment) |
Important Legal Requirements
Employment Requirement
The nurse/staff member must usually be employed by (or contracted to) the billing provider.
Supervision & Care Plan Initiation
The provider (MD/NP/PA) must initiate the care plan first. A nurse cannot simply find a patient and start CCM/RPM on their own — the doctor must order it.