CMS Will Eliminate Consultation Codes – Effective January 1, 2010

2009-12-10

The Centers for Medicare and Medicaid Services (CMS) has announced in its final Medicare Physician Fee Schedule (MPFS) for 2010 that it will be eliminating the use of all consultation codes in the fee-for-service program. After January 1, 2010, CMS will reject submission of consult codes. CMS stated in the proposed rule and reiterated in the final rule that it believes the rationale for differential payment for consultation services is no longer supported because documentation requirements are now similar across all evaluation and management services. This decision may not necessarily apply to Medicare managed care plans known as Medicare Advantage. Physicians should check with individual plans to understand how each will be implemented. 

This policy change will entail the following:

  • CMS will eliminate the use of all consultation codes, except for telehealth consultation services.
  • Providers are instructed to bill an initial or, if appropriate, established visit code (office, hospital, or nursing facility) in lieu of a consultation code.
  • In order to maintain budget neutrality, CMS will increase the work Relative Value Units (RVUs) for the new and established office visits, increasing the work RVUs for initial hospital and initial nursing facility visits, and incorporating the increased use of these visits into practice expense and malpractice RVU calculations.
  • In order to preserve the ability for practitioners to provide and bill for initial inpatient consultations delivered via telehealth, CMS has created three G codes (G0425, G0426, and G0427) specific to the telehealth delivery of initial inpatient consultations.
  • CMS will create a modifier to identify the admitting physician of record for hospital inpatient and nursing facility admissions. This modifier will distinguish the admitting physician of record who oversees the patient's care from other physicians who may be furnishing specialty care.

ASH has been in contact with CMS on this important issue, voicing that the change is very problematic and if it cannot be delayed CMS must provide adequate educational materials. CMS has not yet released any guidance on how to handle these coding changes. ASH will provide this information as soon as it is received.

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