Group by all and Nulls

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This should work the same way in Access (I think):

Select Distinct v.doctorID, p.procedureKey, (Select Count(procedureKey) From tblVisit Where procedureKey = p.procedureKey And doctorID = v.doctorID) As myCount
From xTblProcedureKey As p, tblVisit As v
Where p.procedureKey In ('99211','99212','99213','99395','99396','99397')
And v.procedureKey In ('99211','99212','99213','99395','99396','99397')
And v.postingDate between '9/1/2004' and '9/30/2004'
Order By v.doctorID, p.procedureKey