The Centers for Medicare and Medicaid Services has released its final 2010 Physicians Fee Schedule. One of the most significant changes was the elimination of payment for CPT consultation codes codes as of January 1, 2010.
You can still bill for consulting services, 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. Consulting 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. As of January 1, 2010, CPT codes in the inpatient hospital setting (99221-99223) should be used in place of inpatient consulting codes (99251-99255), and for nursing facility consulting use codes (99304-99306).
4. To distinguish the difference between the admitting doctor of record from the consultants for initial hospital inpatient and nursing facility admissions, CMS will develop a modifier. Currently, modifier “AI” is for principal doctor of record; however Medicare has not finalized the modifier to be used for consulting.
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 Evaluation & management payments is approximately 6% for outpatient/office codes and 2% for inpatient codes above 2009 levels.
An important note regarding commercial or private insurance. No information has been released by other third party payers regarding payment for codes for consulting codes as of yet. However, if a patient has Medicare as a secondary payer, a decision will need to be made by the physician as to how you will report the consultation.
Any consultation claim filed with a commercial insurer such as Blue Cross or Aetna who is primary using the eliminated consultation codes when Medicare is secondary would result in a denial for the secondary claim by Medicare. In those instances where Medicare is secondary, you will need to follow the guidelines from above.
One more note. If you have not brought your enrollment information up to date with CMS since November 2003, you must do so by April 5, 2010. Although enrolled in Medicare, many healthcare providers who are eligible to refer Medicare beneficiaries to other Medicare providers or suppliers for services do not have current enrollment records in Medicare. A current enrollment record is one that is in the Medicare provider enrollment, chain and ownership system (PECOS) and also contains the doctor’s national provider identifier (NPI).
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