Primary Care Coding Alert

The AMA tried to end the transfer of care versus consultation debate by adding new definitions and guidelines to CPT 2010.

CPT 2010 introduces a definition for transfer of care and revises the definition of a consultation (99241-99255). These guidelines are aimed at helping providers, coders, and auditors distinguish between the two.

In the E/M Services Guidelines, the AMA defined transfer of care and attempted to distinguish a transfer from consultations, explained Peter A. Hollmann, MD, AMA CPT editorial panel vice chair, in "Evaluation and Management Services" at the AMA CPT and RBRVS 2010 Annual Symposium in Chicago. "A consult is ... when a physician or other appropriate source has requested an opinion, [and] a transfer of care is where the physician takes over patient care."

In the Definitions of Commonly Used Terms, CPT 2010 expands the Concurrent Care entry to "and Transfer of Care." CPT defines transfer of care as:

"the process whereby a physician who is providing management for some or all of a patient's problems relinquishes this responsibility to another physician who explicitly agrees to accept this responsibility and who, from the initial encounter, is not providing consultative services. The physician transferring care is then no longer providing care for these problems though he or she may continue providing care for other conditions when appropriate. Consultation codes should not be reported by the physician who has agreed to accept transfer of care before an initial evaluation but are appropriate to report if the decision to accept transfer of care cannot be made until after the initial consultation evaluation, regardless of site of service."

In 2009, CPT defines a consult as "a type of service provided by a physician whose opinion or advice regarding evaluation and/or management of a specific problem is requested by another physician or other appropriate source." In contrast, revised and added language for 2010 reads, "A consultation is a type of evaluation and management service provided by a physician at the request of another physician or appropriate source to either recommend care for a specific condition or problem or to determine whether to accept responsibility for ongoing management of the patient's entire care or for the care of a specific condition or problem."

CPT added language to the end of the consultation definition to clarify that in a consultation the consulting physician can advise and treat. "CPT's definition is now as vague as Medicare's was," exclaims Betsy Nicoletti, MS, CPC, in The Journal of Medical Practice Management audio conference "No More Consults?" It's a transfer if you can answer "yes" to any of these statements: 􀀳 Referring physician will not continue to see patient at all

-- Referring physician will not continue to see patient for that condition

-- Referring physician made a diagnosis, contacted specialist, and specialist agreed to treat patient for that condition prior to setting up appointment.

"Though we can not bill the consult codes to Medicare, we should still be treating the encounter the same way we would have treated a consult in the past. Except now, the reporting codes have changed for Medicare," explains Christie Thomas, CPC, PCS, of Mercy Physicians Group in Fort Scott, Kan. The visit's intent should determine the type of visit from a CPT perspective.

Finally, CPT closed the door on any debate on applicable codes for a transfer of care (TOC). The AMA added a notation to the transfer of care directing you to the appropriate codes to report when the physician is performing TOC rather than a consult, Hollmann pointed out.

In the office setting, you'll use an office visit (OV) code (99201-99215). "Services that constitute transfer of care (i.e., are provided for the management of the patient's entire care or for the care of a specific condition or problem) are reported with the appropriate new or established patient codes for office or other outpatient visits, domiciliary, rest home services, or home services," according to a note under the Office or Other Outpatient Consultations subsection.