Advocacy and policy news for internists

Medicare Eliminates Consultation Coding for 2010

In a dramatic shift in coding policy, beginning Jan. 1, 2010, Medicare will no longer recognize the Current Procedural Terminology (CPT) consultation codes. The 2010 Medicare Physician Fee Schedule that was published at the end of October finalized a proposal to no longer recognize office/outpatient and inpatient consultation codes. Physicians will continue to be paid for providing consultation services, but they will need to adjust their billing to use new codes.

ACP has contacted the Centers for Medicare & Medicaid Services (CMS) to request that they delay the implementation of these coding changes. The College is also working with our subspecialty advisory group, the Subspecialty Advisory Group on Socioeconomic Affairs, to come up with recommendations to CMS about specific issues that need to be addressed before proceeding with the policy change. Among the most pressing of those issues is the need for CMS to provide basic notice of the new policy to physicians while allowing them adequate time to prepare for the change.

In order to compensate for the elimination of the higher reimbursement paid for consultation codes, CMS is adjusting the payment rates for the evaluation and management codes that are being used in their place. The physician work component of payments for office visit services will be increased by 6 percent, and the physician work component for initial hospital visit services will be increased by 2 percent. CMS estimates that with these changes the financial impact for eliminating the consultation codes will be modest. General internal medicine revenues would increase by 1 percent, while most internal medicine subspecialty revenues would decrease by 1 percent. More information about the financial impact of the changes is included in ACP's summary of changes in the 2010 fee schedule.

While the College is still advocating for a delay in the new policy, with Jan. 1 fast approaching, physicians should begin familiarizing themselves with the upcoming changes. The consultation codes will be replaced with a varying list of office visit and hospital care codes.

  • For billing Medicare for office or outpatient consultation services, physicians should generally bill a new patient visit (CPT 99201-99205).
  • If the patient has been seen by the consulting physician in the previous three years, the visit should be billed as an established patient visit (CPT 99211-99215).
  • Medicare inpatient consultations should be billed with initial hospital care codes (CPT 99221-99223).
  • When admitting Medicare patients to hospitals or nursing facilities, the admitting physician should use the initial hospital care CPT codes or initial NF care codes (99304-99306), with the new "-AI" modifier.
  • Follow-up telehealth inpatient consultations provided to a patient in the hospital or skilled nursing facility setting should be billed with new HCPCS codes G0406-G0408.

It is important to note that while the consultation codes still appear in the 2010 CPT codebook, they are there for use with insurers other than Medicare. For billing to Medicare, physicians will need to use office/outpatient visit or hospital care codes, instead of the consultation codes.

Office ConsultationNew or established patient office visit
Inpatient hospital consultationInitial hospital care
Inpatient hospital admission visit Initial hospital care, with modifier "-AI"
Nursing facility consultationInitial nursing facility care
Nursing facility admission Initial nursing facility care, with modifier "-AI"
Follow-up telehealth or SNF inpatient consultationsNew HCPCS codes G0406 thru G0408

Additional information about Medicare changes in 2010 can be found in the Frequently Asked Questions about the Medicare 2010 Physician Fee Schedule, on the College's Web site. Also, as the New Year approaches, check the Running a Practice section of the Web site for updates on the consultation coding issue as more guidance from CMS becomes available.

December 10, 2009