Gastroenterology Coding Alert

Question: I recently participated in a teleconference covering 2006 changes for Medicare rules regarding consults. The presenter stated that we cannot bill a shared/split visit as a consult. The verbal explanation stated that the doctor must perform all elements of the E/M himself, and a nonphysician practitioner (NPP) cannot be used to collect information such as history of present illness; review of systems; or past, family and social history. Is this correct? Our doctors now use a preprinted ROS for the patients to complete, but an NPP charts the reason for the visit and PFSH and, if the gastroenterologist orders an endoscopy, explains the procedure and risks. 

Kentucky Subscriber

Answer: CMS did make some changes to Medicare rules this year. The good news is that CMS specifically states that your NPPs can report and request consultations. The bad news is that CMS has also clarified that you cannot report a consultation that is a shared or split visit between the gastroenterologist and the NPP.

Often in gastroenterology practices, a nurse practitioner does the patient workup and then the gastroenterologist does a key portion of the service face-to-face and bills for the whole visit. CMS specifically states that this is not permissible with consultations.
 
Therefore, when your gastroenterologist performs a consultation, your office's nurse practitioner or physician assistant can perform only the review of systems or past, family and social history. The physician must perform the exam and medical decision-making (MDM).

You can find this documentation in the Internet-Only Manual (IOM) 100-04, 12, 30.6.10.