# Final Rule/CMS



## RebeccaWoodward* (Nov 25, 2009)

http://edocket.access.gpo.gov/2009/pdf/E9-26502.pdf



Ok...*Consultations start on page 31*


----------



## tammster (Nov 25, 2009)

Thank you!!


----------



## RebeccaWoodward* (Nov 25, 2009)

I'm rather irritated...

“The determination of the appropriate visit code should be made solely on the basis of the existing rules and guidelines for the use of the relevant visit codes (for example, office visit or inpatient visit), without any reference to the guidelines that have been employed for the use of the consultation codes. The guidelines for use of the visit codes are well established and well understood. Therefore, we do not believe that it is necessary to provide any coding crosswalk or guidelines for translating the consultation code requirements into the appropriate visit codes. Commenters are correct that while there are five consultation codes, there are only three initial visit codes, that none of the E/M codes reflect the face-to-face times reflected in the highest level consultation codes, and various other differences between the two sets of codes. Nevertheless, it remains possible to determine the appropriate visit code for the services in question by applying the appropriate guidelines and requirements for using those codes."

Bologna!...there are still many unanswered questions!!  At least for me....


----------



## tammster (Nov 25, 2009)

I agree.  I was hoping for more details.  This left a lot of unanswered questions


----------



## LLovett (Nov 30, 2009)

The thing they are leaving out in saying that the guidelines are well established and understood is the fact that those currently using consult codes are not the ones that understand the other codes since they don't use them!

I just ran a report of some of my specialists that will be hit hardest by this. So far this year not a single 99221-99223 has been charged but they have used 288 inpatient consults.

It is going to be a very sharp learning curve.

Laura, CPC, CEMC


----------



## mitchellde (Nov 30, 2009)

I hear you, I have been teaching this since it was proposed and there are many unhappy people and then they turn on me like I was the one that created this proposal!  But everyone is clutching and wondering what to do.  So many people are still uninformed of this change, so what do you want to bet that come February we still have postings regarding why their consult did not get paid?
Also did you see the bit about when Medicare is secondary?  

In those cases where Medicare is the secondary payer, physicians and billing personnel will first need to determine whether the primary payer continues to recognize the consultation codes. If the primary payer does continue to recognize those codes, the physician will need to decide whether to bill the primary payer using visit codes, which will preserve the possibility of receiving a secondary Medicare payment, or to bill the primary payer with the consultation codes, which will result in a denial of payment for invalid codes."


----------



## RebeccaWoodward* (Nov 30, 2009)

I'm hearing from other coders that when they've contacted their "main" carriers for their states, some carriers had no idea what they were talking about.  They actually had to fax the carrier a copy of the reg.  The more and more I think about it...some things are starting to make sense. Excerpt from reg...

*"The determination of the appropriate visit code should be made solely on the basis of the existing rules and guidelines for the use of the relevant visit codes (for example, office visit or inpatient visit), without any reference to the guidelines that have been employed for the use of the consultation codes. The guidelines for use of the visit codes are well established and well understood. Therefore, we do not believe that it is necessary to provide any coding crosswalk or guidelines for translating the consultation code requirements into the appropriate visit codes."*

Based on that statement, it's critical to know chapter 12 of the Medicare manual....inside and out...

Now...I would like some opinions on this scenario...


 If my physician performed a “so called inpatient consultation”  POS 21,  he will bill 99221-99223 (assuming he met the minimal requirements for 99221).  Now when this patient is transferred to IRC (POS 61), he would not bill another 99221-99223 but rather a subsequent visit? 

Physician Services Involving Transfer From One Hospital to Another; Transfer Within Facility to Prospective Payment System (PPS) Exempt Unit of Hospital; Transfer From One Facility to Another Separate Entity Under Same Ownership and/or Part of Same Complex; or Transfer From One Department to Another Within Single Facility 


Physicians may bill both the hospital discharge management code and an initial hospital care code when the discharge and admission do not occur on the same day if the transfer is between:

                        Different hospitals; (NO)



                        Different facilities under common ownership which do not have merged records; or (records are merged)



                        Between the acute care hospital and a PPS exempt unit within the same hospital when there are no merged records. (NO)



*In all other transfer circumstances, the physician should bill only the appropriate level of subsequent hospital care for the date of transfer*.

I'm saying subsequent visit for the transfer to IRC...any disputes?


----------



## todd5400 (Dec 1, 2009)

Soooo if we are not going to be using the consult codes do we have to worry about having the referring doctor listed????

Mary, CPC


----------



## nc_coder (Dec 2, 2009)

ok- next question

I informed my doctors of this final rule this morning and all heck has broken loose.

One question asked is how do we bill for hospital consults. "It can't be an h&p if the patient is already admitted".  One of my coders said she read there would be a modifier we can use that differentiates the admitting physician from the "consulting" physician.  Does anyone else know anything about this?

Maybe we will eventually get this figured out- just in time for them to change the rules again!


----------



## tammster (Dec 2, 2009)

Does anyone have any idea when they are going to release the information about this modifier?  I read somewhere that if no one bills with this modifier that all 'initial' hospital care charges will be subject to review...

Then, doesn't it make more sense to give us a modifier for the consulting physician to append to his claim?  That way, we aren't at the mercy of the admitting physician in order to have our claims paid in a timely manner.  Just a thought.


----------



## RebeccaWoodward* (Dec 2, 2009)

Tentatively, the modifier for the *Admitting *physician is *AI*, but until competley finalized, this could be subject to change

AI=*Principal physician of rec	* 

http://www.cms.hhs.gov/apps/ama/license.asp?file=/HCPCSReleaseCodeSets/Downloads/10anweb.zip


----------



## RebeccaWoodward* (Dec 2, 2009)

*The admitting physician of record will be required to append the specific modifier to the initial hospital care or initial nursing facility care code which will identify him or her as the admitting physician of record who is overseeing the patient's care*


http://edocket.access.gpo.gov/2009/pdf/E9-26502.pdf

Page 39

The link takes a few seconds to open~


----------



## tammster (Dec 2, 2009)

Thanks Rebecca!!


----------



## Love Coding! (Dec 2, 2009)

*Modifier AN*

I heard that there will be a modifier AN.  Here is the link if anyone is interested.  It is on the Coding News website.

http://codingnews.inhealthcare.com/...ges-to-2010-cpt-inpatient-consultation-codes/

Does anyone know what CPT codes will be used in replace of the inpatient hospital consult codes?

Thanks!

dscoder74


----------



## RebeccaWoodward* (Dec 2, 2009)

I heard that too but it's not on the HCPCS grid for 2010.  Also, the folks that attended the AMA Symposium in Chicago stated that the CMS contractor representatives indicated that the modifier would be AI.  Won't you be glad when the guessing game is over??


----------



## Love Coding! (Dec 2, 2009)

I heard that, I emailed Noridian this morning to try to get a more clearer answer.  I am guessing I will be waiting a long time.  As I have mentioned to collegues of mine too many opinions out there not concrete answer.  Why does Medicare give us information in bits and pieces?  I don't understand it. 

Have a great day everybody!

dscoder74


----------



## tammster (Dec 2, 2009)

Cahaba had a webinar today regarding 2010 Medicare updates.  Someone asked about the consultation codes being eliminated.  The presenters did NOT even know that the final decision had been made.  I was shocked about that, since it is such a major change.


----------

