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.
The Office of Inspector General (OIG) has posted its work plan for FY 2010; What does it mean for Anesthesia Practices
The Office of Inspector General (OIG) has posted its work plan for FY 2010. Of particular interest to anesthesiologists and pain physicians, the work plan includes the following areas of focus:
1. The OIG will “review Medicare claims to determine the appropriateness of Medicare Part B payments for transforaminal epidural injections” (page 19).
2. The OIG also review the extent to which physicians reassign their Medicare benefits to other entities, as well as provider compliance with Medicare assignment rules (pages 17-18).
3. The OIG will review industry practices related to E&M billing during the global surgery period to see if industry practices have changed since the global surgery fee concept was developed in 1992 (page 15). The results of this review will be of interest, as anesthesiologists sometimes bill for E&M services pertaining to post-op pain services during the global surgery period.
4. The OIG will review physician claims for proper place-of-service coding (page 15).
