General Surgery Coding Alert

Requesting physician must note consult in plan of care

The -Three R-s- aren't enough anymore for reporting a consult. CMS weighs in with new rules that will change document requirements for consultations.

Cautious coding experts have long recommended that both the requesting and consulting physician note the request and reason for a consultation in the patient's medical record. A recent -Medlearns Matters- article, however, now stipulates that such documentation is not merely -best practice- but absolutely required in all instances. Docs Must Cooperate on Documentation Starting Jan. 17, to report a consult (99241-99255), the consulting physician must receive and document a request from an appropriate source, and -the need for consultation (i.e., the reason for a consultation service) shall be documented by the consultant in the patient's medical record and included in the requesting physician or qualified NPP's plan of care in the patient's medical record,- according to Medlearn Matters article MM4215 [emphasis added].

What's the difference: These requirements--that the requesting physician must document the reason and request in the patient's plan of care--are new.

In the past, Medicare rules did not specifically state that consultation requests had to be in writing, nor did they specify that the requesting physician had to note the request in the patient's record (see -Written Consult Request Isn't Mandatory- on page 54 of the July 2005 General Surgery Coding Alert).

Example: If one physician meets another in the hallway and verbally requests a consult, they should both document that fact, insisted CMS official Kit Scally during a Jan. 20 physician Open-Door Forum. If the physician phones in the consult request to the other doctor's staff, both practices should document that circumstance too, she said.

Potential problem: -The request and reason have to be in both charts,- says Barbara J. Cobuzzi, MBA, CPC, CPC-H, CHBME, president of CRN Healthcare Solutions, a coding and reimbursement consulting firm in Tinton Falls, N.J. -But the consultant only has power over their own chart. The specialists will have to educate the requesting doctors to make sure they make notations of these consultation opinion requests in their charts so that the loop is closed.-

The new requirement for the requesting physician to document the request for a consult is -a Catch-22,- says Steven Levinson, MD, of Fairfield, Conn., author of Practical E/M: Documentation and Coding Solutions for Quality Patient Care. -If I call the doctor who's referring me patients every six days and say, -Please send me a photocopy of your chart that shows you documented the consult,- I soon will not have any consults.- Use a Standard Sheet to Make It Easy One way to ensure that all the necessary documentation is in place for your office to report a consultation is to use a [...]