Medicare Requires New Consultation Billing Guidelines

The CMS has released its final 2010 Physicians Fee Schedule. One of the most significant changes was the elimination of payment for consultation codes as of January 1, 2010.

This does not mean you can no longer do consultative work, it just means that you will have to bill these services differently than you do now. Here are the facts regarding this new ruling and the potential impact on your practice.

1. Consultation codes 99241-99245 (outpatient/office) and 99251-99255 (inpatient) have been eliminated effective January 1, 2010. Telehealth consultation G-codes (G0425-G0427) will not be eliminated.

2. Starting January 1, 2010, CPT codes for new (99201-99205) or established (99211-99215) patients should be used to replace consultations in the office/outpatient setting.

3. Starting January 1, 2010, CPT codes in the inpatient hospital setting (99221-99223) should be used to replace inpatient consultation codes (99251-99255), and for nursing facility consultations use codes (99304-99306).

4. To distinguish the difference between the admitting physician of record from the consultants for initial hospital inpatient and nursing facility admissions, CMS will develop a modifier. Currently, modifier "AI" is for principal physician of record, however Medicare has not finalized the modifier to be used for consultations.

5. Medicare states that its changes are budget neutral. RVUs for all E/M codes have been increased in an attempt to offset the fees lost from the elimination of consultation codes. The increase in E/M payments is approximately 6% for outpatient/office codes and 2% for inpatient codes above 2009 levels.