An MD used case management (Comp Med Svc Pharm Mgmt<20) to fill a prescription for a client who could not make their appt but was assessed briefly over the phone?
The case management code is OK but there is another option. Since this was a telephone based service the med support code that I would have used is 90899-8. The reason is that the other code (I think you are referring to the M0064 code or maybe the 90862 code) requires a face-to face service. I also should point out that M0064 can only be used for Medicare clients and only if the situation fits.

In the insurance world outside of the county no telephone services are billable at this time. MDs may be choosing the case management code for the reason that they think that there is no legitimately billable med services code. They are right for the most part. But the reason we created the 90899-8 code is because in the insurance world of the county a non face-to-face service is billable as a medical service. We had to create a code that does not exist in the insurance world outside of the county in order to bill for that type of non face-to-face service. 

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