Moderate conscious sedation 99143-99145

We would like clarification regarding the definition of the moderate conscious sedation codes 99143-99150.

The definition of 99143 is moderate sedation services (other than those services described by codes 00100-01999) provided by the same physician performing the diagnostic or therapeutic service that the sedation supports, requiring the presence of an independent trained observer to assist in the monitoring of the patient's level of consciousness and physiological status; younger than 5 years of age, first 30 minutes intra-service time.

Does “physician” mean “physician” or would a mid-level provider (PA, APN) qualify as “physician?”

We have a non-facility office so we understand we would not be able to bill 99148-99150.

If a mid-level provider qualifies to perform the moderate sedation, can the physician, Dr. J perform the procedure and the APN K be the trained observer and bill 99143 – 99145?

We thank you in advance for your help with these questions.