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CMS Eliminates Payment for Consultations Effective January 1, 2010

The Centers for Medicare and Medicaid Services (CMS) finalized the decision to eliminate the payment of all consultation codes (inpatient and office/outpatient codes for various places of service except for telehealth consultation G-codes) submitted on Medicare claims, beginning January 1, 2010. Physicians should stop submitting the consultation codes on their Medicare claims and use the appropriate visit code instead.

Consultations have been historically paid at a higher rate than new and established office visits and initial hospital visits. Confusion and disagreement about the proper use of the consultation codes has always been an issue since their creation in 1990. Although CMS worked to educate regarding the proper use of the consultation codes, errors in reporting these codes did not improve according to the Office of Inspector General.

“Transfer of care” guidelines were revised to better define and distinguish them from consultations, but CMS did not believe that the new definitions would clarify all the confusion and moved forward with their decision to eliminate reimbursement for the consultation codes under the Medicare physician fee schedule (MPFS). The consultation codes have not been eliminated from the CPT code set, these codes can still be submitted to Medicare with the new guidelines, but payment will not be received. Commercial payers will need to be queried individually to determine if they will be changing their policies regarding payment of consultation services.

Effective January 1, 2010, the admitting physician should bill an initial hospital care (99221-99223) for their first visit during a patient’s admission to the hospital instead of the consultation code that may have been previously reported. CMS will be creating a modifier to identify the admitting physician of record for hospital inpatient admissions. This modifier will identify the admitting physician of record who oversaw the patient’s care from other physicians who furnished specialty care. Currently, consultation services are mostly billed by specialty care physicians. The admitting physician of record must append the modifier to the initial hospital care. Subsequent care visits will be reported with subsequent hospital care codes (99231-99233).

Source: Nelson, Tanai S. “CMS Eliminates Reimbursement for Consultations” AHIMA CodeWrite Monthly E-Newsletter December 2009.