CMS Eliminates Consultation Codes – FAQs, Crosswalk and Guidance Available

In the final 2010 physician fee schedule, the Centers for Medicare & Medicaid Services (CMS) eliminated the use of all consultation codes (inpatient and office/outpatient codes for various places of service except for telehealth consultation G-codes) on a budget-neutral basis. Instead, CMS increased the work relative value units (RVUs) for new and established office visits, as well as initial hospital and initial nursing facility visits.

Recently, CMS released Transmittal 1875 and MLN Matters 6740  which provides guidance to practices on how to bill for services for Medicare Part B patients now that consultation codes have been eliminated. CMS announced that the modifier to distinguish the admitting physician from other physicians who may furnish care is “-AI.” The admitting physician should append the “-AI” modifier along with initial visit codes to their claims while other physicians who perform initial evaluations should only bill the appropriate evaluation and management (E/M) code. CMS instructs providers to select the appropriate E/M codes based on the content of services provided and not the level of documentation. According to agency, documentation should merely support the level of services provided. CMS advises practices to take time and/or controlling factors into consideration when determining the level of service provided.