Otolaryngology Coding Alert

Question: How do you code a nonphysician practitioner report of a consultation that she performs on a hospital inpatient?

Arizona Subscriber

Answer: The key is reporting the inpatient consultation under the NPP's NPI. Medicare allows you to report services that the NPP provides in a hospital as long as you don't report the services "incident to." You may only report incident to services in the physician's office and not in an outpatient facility (apart from the Rural Teaching Exception) or an inpatient facility.

Therefore, if your NPP provides a consult in the hospital and documents the "three R-s" of the consultation (request, review, and report back to the requesting physician or proper notation in the shared record), you can report the appropriate consult code (99241-99245 or 99251-99255, depending on whether the patient is outpatient or inpatient) under the NPP's NPI.

Also note: Because a consultation, no matter the site of service, involves evaluating a new problem, an NPP may never provide this service incident to and must always provide consultations only under her own NPI.

Watch out: You may have to document the supervision requirements for some insurers. Check with your payers before you set up practices for the NPPs. And check your state and hospital scope-of-practice guidelines before you bill an NPP's consult; state guidelines can vary.