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CMS Eliminates MedicarePayment for Consultation CodesPrepared by the UFJHI Office ofPhysician Billing Compliance
Outline Reasons for ChangeEffective DateNew ModifierImpact on Other PayersImpact on MedicareSecondary Claims Code Selection– Office/Outpatient– Inpatient Hospital– Inpatient SNF/NF Global Surgery AllowanceChanges Budget Neutrality and FeeChange Crosswalk Telehealth Consults Consult CodingConversion Chart Q&APrepared by the UFJHI Office ofPhysician Billing Compliance
Reasons for Change Divergent interpretations Lack of proper documentation to support consult code(request, report) Continued lack of agreement or understanding ofMedicare policy despite numerous educationalinitiatives One of the two goals for development of new codesnot panning out AMA CPT definition provides no clear definition oftransfer of care and is ambiguous and confusingPrepared by the UFJHI Office ofPhysician Billing Compliance
Reasons for Change Associated physician work for consult is clinicallysimilar to other visits Written report not sufficient reason for higherreimbursement as all E/M services requiredocumentation Preparation & submission of the consultant’s report nolonger major defining aspect of consultation buthigher payment remainsPrepared by the UFJHI Office ofPhysician Billing Compliance
Effective DateThe changes are effective January 1, 2010Prepared by the UFJHI Office ofPhysician Billing Compliance
New Modifier New modifier: AI – “Principal Physician ofRecord” To be used with inpatient hospital admissioncodes and initial nursing facility visit code In both these settings – new modifier will beappended to initial visit code billed by theadmitting physician of recordPrepared by the UFJHI Office ofPhysician Billing Compliance
New Modifier Admitting physician of record physician whooversees the patient’s care from other physicianswho may be furnishing specialty care May only be one admitting physician of record perAMA CPT coding rules and Medicare Part Bpayment policyPrepared by the UFJHI Office ofPhysician Billing Compliance
Impact on Other Payers Concern expressed to CMS by providercommunity about the effects of this proposal oncoordination of payment between CMS and otherpayers CMS basically provided a “non-answer” to thisconcern by indicating that they have no authorityto determine which services will be recognizedand paid by other third party payersPrepared by the UFJHI Office ofPhysician Billing Compliance
Impact on Other Payers Medicare will no longer recognize the consultationcodes regardless of what other third party payersrecognize CMS suggests providers consult with thesecondary payers in order to receive secondarypayment and to determine how those payers wantbills to be submittedPrepared by the UFJHI Office ofPhysician Billing Compliance
Impact on MedicareSecondary Claims Medicare will no longer recognize consultation codessubmitted on Medicare secondary payer bills Per CMS, if the primary payer continues to recognizeconsult codes, the physician will need to decidewhether to bill the primary payer using visit codes(which will preserve the possibility of receivingMedicare secondary payment) or to bill the primarypayer with the consult codes which will result in aMedicare secondary payer denialPrepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Office/Outpatient Use the appropriate office/outpatient visit code (9920199205 or 99211-99215) Consults were for new and established patients but visitcodes are separated into new or established patients Refer to definition of new patient for proper codeselection Visits performed in the OBU by physician other than thephysician who admits and is responsible for the patientwhile in OBU should be coded as office/outpatient visitPrepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Office/Outpatient “Preoperative consultations” have been payable fornew or established patients performed by a physicianor qualified NPP at the request of a surgeon as long asthe service was medically necessary and not routinescreening Use appropriately documented office/outpatient visitcode (99201-99205 or 99211-99215) instead ofconsult codes Refer to definition of new patient for proper codeselectionPrepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Office/Outpatient Medicare’s definition of new patient:A patient who has not received anyprofessional services, i.e., E/M serviceor other face-to-face service (e.g., surgicalprocedure) from the physician or physiciangroup practice (same physician specialty)within the previous3 years.Prepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Office/Outpatient If an emergency department physician requeststhat another physician evaluate a given patient inthe emergency room, the other or “consulting”physician should bill an emergency departmentvisit unless the patient is admitted to the hospital If the patient is admitted to the hospital by the“consulting” physician, the “consulting” physicianwould bill the appropriate initial hospital carecode (OBU or inpatient)Prepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Office/Outpatient If there is any silver lining or positive spin on thischange it is that Medicare policy did not allowconsults to be billed as shared encounters betweenphysicians and NPPs but the shared visit policycan be applied to initial hospital care visits Refer to Medicare Claims Processing ManualInternet Manual 100-04, chapter 12, § 30.6.1 (B)Prepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Inpatient Hospital Inpatient consult codes (99251-99255) replacedwith initial hospital care codes (99221-99223) Use prolonged attendance codes to take intoaccount face-to-face times over and above thetimes specified in the admission codes “Consulting” physician would never bill 9923499236 as not admitting physician of record socould not discharge same day as admitPrepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Inpatient Hospital Admitting physician of record bills initial inpatient visit asappropriately documented initial inpatient hospital carecode in range of 99221-99223 and appends designatedmodifier “Consultant” bills initial encounter as appropriatelydocumented initial inpatient hospital care code in range of99221-99223 but does NOT append designated modifier Subsequent encounters coded as subsequent hospital visits(99231-99233) by both admitting physician of record andany “consultants”Prepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Inpatient SNF Initial visit in a SNF must be furnished by aphysician Initial visit in a NF may only be furnished by anenrolled NPP, not employed by the facility, whenstate law permits this Follow same provider restrictions for readmissionsto SNFs or NFs Refer to Medicare Claims Processing ManualInternet Manual 100-04, chapter 12, § 30.6.13APrepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Inpatient SNF Both admitting physician of record and “consultant”bill an initial nursing facility care code (99304-99306range) for their first visit during a patient’s admissionto the nursing facility Admitting physician of record appends designatedmodifier to initial nursing facility care code “Consultant” does NOT append designated modifier If “consultant” an NPP, refer to Medicare ClaimsProcessing Manual Internet Manual 100-04, chapter12, § 30.6.13APrepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Inpatient SNF Use prolonged attendance codes to take intoaccount face-to-face times over and above thetimes specified in the admission codesPrepared by the UFJHI Office ofPhysician Billing Compliance
Code Selection –Inpatient SNF Subsequent encounters (other than discharge) areto be coded as subsequent nursing facility carecodes (99307-99310) by both admitting physicianof record and any “consultants”Prepared by the UFJHI Office ofPhysician Billing Compliance
Impact onGlobal Surgery Allowance CMS agreed to extend the incremental work RVUincrease to the E/M codes that are built intoprocedures with global packages of 10-day and90-day follow-up periods Increases in payments for these services will besmall because visits are a small portion of the totalglobal paymentPrepared by the UFJHI Office ofPhysician Billing Compliance
Budget Neutrality &Fee Change Crosswalk CMS will make this change budget neutral for thework RVUs by increasing the work RVUs as follows:– New and established office visits by @ 6%– Initial hospital and nursing facility visits by @ 2% Crosswalk developed solely for purposes of makingthe requisite budget neutrality calculations Crosswalk is not for coding Estimations used on creating crosswalk based onstandard assumptions and utilization dataPrepared by the UFJHI Office ofPhysician Billing Compliance
Telehealth Consults HCPCs Level II G-codes to be created for initialinpatient consults delivered via telehealth Currently there are only HCPCs Level II codes forinpatient follow-up telehealth consults Consults furnished via telehealth can facilitateprovision of certain services and/or medical expertisethat might not be available to a patient located at anoriginating site RVUs to be crosswalked to initial hospital care codes99221-99223Prepared by the UFJHI Office ofPhysician Billing Compliance
Prepared by the UFJHI Office ofPhysician Billing Compliance
Q&AQ: Will we have to remove consults from our superbills or encounter forms?A: No. Payors other than Medicare will still recognize consultation codes.Q: Will this have an impact on our current referral process or appointmentscheduling process?A: No. The only difference is the code selected when a charge is billed toMedicare.Q: Why can’t we just crosswalk the consult codes to visit codes for Medicare?A: Because there are different service and documentation requirements for visitsthan there are for consultations. The proper visit code must be selected basedon the patient’s status and the level of care provided and documented.Q: What happens if I accidentally bill a consultation code to Medicare?A: Medicare would deny the charge. Once the denial was received, the businessgroup could rebill Medicare with the correct procedure code. Compliance isworking with the faculty practice plan to initiate a system edit which wouldprevent the billing of consultation codes to Medicare.Prepared by the UFJHI Office ofPhysician Billing Compliance
References Medicare Program; Payment Policies Under the Physician FeeSchedule and Other Revisions to Part B for CY 2010. [CMS-1413-FC]The Office of the Federal Register. 009-26502 PI.pdf . Accessed November 4, 2009. Medicare Claims Processing Manual. Internet Only Manual 100-04,chapter 12, § § 30.6.1 (B), 30.6.7 (A), 30.6.11 (F), 30.6.13 (A).Accessed November 5, 2009. The American Medical Association. CPT 2009 Professional Edition. CMS. Transmittal 808. Change Request 4246. “Nursing FacilityServices (Codes 99304 - 99318).” January 6, 2006.Prepared by the UFJHI Office ofPhysician Billing Compliance
Questions?Call the UFJHI Office of Physician BillingCompliance at (904) 244-2158Prepared by the UFJHI Office ofPhysician Billing Compliance
A: No. Payors other than Medicare will still recognize consultation codes. Q: Will this have an impact on our current referral process or appointment scheduling process? A: No. The only difference is the code selected when a charge is billed to Medicare. Q: Why can't we just crosswalk the consult codes to visit codes for Medicare?
