|
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:
- Billed with wrong type or level of
consultation 47%
- Services did not meet the
definition of a consultation 19%
- 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
|