Gastroenterology Coding Alert

Question: I know that a nonphysician practitioner and a surgeon can -share- an E/M visit, with the nurse, for instance, taking the history and performing some preliminary work and then handing off the patient to the gastroenterologist for the exam. Although I have not seen anything in writing, I have heard that this practice is unacceptable for consultation services. Is this true?


New Jersey Subscriber


Answer: Coding experts and CMS regulations agree: You cannot bill consults as -shared visits.-

Specifically, the CMS definition of a shared visit says the service must follow all the rules of an -incident-to- office service--which means that there should be an established patient with an established problem. And, generally, these aren't the circumstances with a consult.

Regardless of the patient's status, however, when a requesting physician asks for a consult, he is only seeking your gastroenterologist's opinion, not the opinion of other providers in your office.

Bottom line: Consults are already an area under intense scrutiny by payers and the HHS Office of Inspector General, and you shouldn't place your claims in jeopardy by violating -shared visit- criteria.

Best practice and ethical considerations dictate that the consulting physician should provide the entire service if he wishes to report a consultation. He should not rely on the work or opinions of nonphysician practitioners (who cannot meet the requirements of a consultation service) when reporting either outpatient (99241-99245) or inpatient (99251-99255) consultations.