Alta Partners News & Tips.  Information to Improve your Practice
Volume 1- Edition 1

 

Special Update - The Future of Consultation Codes 

Alta Partners would like to update our clients and colleagues as to the new CMS (Medicare) rule affecting consultation services as of January 1, 2010. 

 Since the establishment of Consultation codes in 1990 by the American Medical Association (AMA) Current Procedure Terminology (CPT) Editorial Panel, CMS has continually tried to improve proper billing requirements with the health care providers. Consultation codes were intended to be used by providers when they requested an opinion, advice, recommendation, suggestions, direction or counsel from another provider.  Consultation service must be documented in the medical record and a written report must be provided to the requesting provider.

 From 1999 to 2006, Medicare contractors worked with health care providers educating them about the criteria and proper billing for all levels of consultations services.  In March of 2006 The Office of the Inspector General (OIG) issued a report entitled, “Consultations in Medicare: Coding and Reimbursements”.  The report was intended to address the appropriateness of consultation codes billed by providers. The report, based on 2001 Medicare paid claims, indicated that about 75% of services paid did not meet all of the requirements for a consultation. The top three reasons are listed below:

  1. Billed with wrong type or level of consultation                                 47%
  2. Services did not meet the definition of a consultation                       19%
  3. Lack of appropriate documentation                                                  9%

In 2006 the CPT Editorial Panel chose to delete the Follow-up Inpatient Consultation codes and the Confirmatory Consultation codes in an effort to improve some of the confusion on the correct usage of these follow up codes.  CMS has also reduced the written reporting requirement for Consultation codes by allowing providers to use any written form of communication. 

Starting in January, Medicare will be making what should be their final change to the consultation codes.  Effective January 1, 2010, Medicare will no longer recognize office consultation codes 99241 – 99245 and inpatient consultation codes 99251 – 99255.  In place of these codes, providers should utilize the appropriate New and Established office visits/out patient, Initial Hospital and Initial Nursing Facility visits. 

 

The elimination of these codes is to be considered, by CMS, as budget neutral.  CMS has taken the payment for consultation codes and distributed them amongst the codes identified above.  It should be noted that since there is not a one-to-one relationship between the consultation codes and evaluation and management codes, providers should refer to the correct coding guidelines to insure their claims are billed appropriately.  Medicare has stated that they will send out more information regarding the coding guidelines over the next few weeks. 

              It should be noted that even though the Evaluation and Management codes do not require a written communication back to the referring provider when a consultation is requested, it is a good business practice to provide some form of written documentation back to the provider that is requesting the consult.

              As of today, Alta Partners is only aware of this change being recognized by Medicare, but other commercial payers have a history of following suit.  Alta Partners will closely watch denials to identify any payers that may start to recognize this change.  If you receive any correspondence in your office regarding this issue, please forward it to our office.  Many payers will correspond with the office address and not the payment address.  We will continue to keep our clients informed of any additional changes.  If you have any questions in the mean time, please contact Jeff Kovacs at (440) 808-3649.

Reference:

Final 2010 Physician Fee Schedule. (2009, October). The Centers for Medicare & Medicaid Services (CMS), p. 162-206