It is very unlikely that your carriers define RNs or LPNs as Qualified Non-Physician Health Care Professionals. A commonly referenced definition of QNHCPs is clinicians who have an NPI, but who are not qualified to render E&M services. Examples are dietitians, physical therapists, and social workers. That is who those Assessment and Management codes are for.
I asked the AAP Coding Hotline about that article earlier this week. She stated that, that article being about 11 years old, has been superceded by new guidance by CPT. (AAP News also may have accepted that article from the Section on Telephone Care without having it first vetted by the coding team.)
MAs, LPNs, and RNs are not QHCPs. That’s why they can’t do the counseling for vaccines and get paid for 90460 (which also has the “physician or otherwise qualified health care practitioner” phrase.) It doesn’t matter how they’ve been trained. (Our clinical supervisor is an RN who’s won our state’s CDC Immunization Award, constantly provides feedback to our IIS and state immunization leadership, sat next to Paul Offit at a national conference once but her vaccine counseling doesn’t count towards 9046x).
There are a few exceptions: a) the payer bends the rules in your favor, as BCBS of Michigan has done if your clinical staff go through their training program; b) a public health exception like RNs who have completed EPSDT training and can bill for checkups in a public health setting.
We have asked AAP News and AAP’s Committee on Coding and Nomenclature to quickly submit a clarification, given everyone’s interest in getting paid for our nurses’ hard work.
In the meantime, if your payer permits audio-only services to qualify telehealth, consider whether billing 99211 for nurse phone assessments would be appropriate.