Practice Management Alert

You Be the Billing Expert:

Watch For Documented Consultation Requests

Question: Doctor A admits patient from assisted care facility. Dr. B does the H & P for a patient that has a Medicare replacement policy on the following day. Can I bill for the Initial Hospital Care (99221-99223)? My understand is that when a patient has a Medicare replacement, that since Medicare no longer pays consult codes, you can use an initial hospital care since we are a specialty and it was his first time visiting the patient in the hospital. Am I correct?

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Answer: There isn’t quite enough info in your question to give you a straight yes or no answer, but here are some general guidelines to get you started in the right direction.

First, you don’t really say whether Dr. A actually did anything other than put a call in to say "admit the patient on my rotation." If all he did was make a call and really didn’t perform a service, then Dr. A shouldn’t bill anything. But assuming that Dr. A performed at least the minimum of a detailed history and exam, in that case, Dr. A would bill the proper 99221-99223 code (Initial hospital care, per day, for the evaluation and management of a patient …) with modifier AI (Principal physician of record).

If Dr. B was called in to do a consult, which it seems your question implies, then yes, Dr. B would bill the initial hospital care code of 99221-99223 as well. Note that there still needs to be that documented request for a consultation even though you aren’t using consultation codes, because the 99221-99223 are really just in place of the consult codes. If Dr. B really just did an H&P without a request for a consult, then Dr. B should bill follow-up inpatient care .

Here’s why: Most Medicare replacements follow Medicare’s rules about no longer using the consultation codes, and using 99221-99223 instead. However, you should not assume that is the case. Check with your payer. Go to their website and such and see if you can find something in writing that states whether or not they accept the consultation codes still.

Also keep in mind that the two doctors should either be from separate practices or separate specialties in order to both bill.

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