Here is how I handle the situation you describe. My threshold is what the provider knows on the outside of the door before he enters a patient's room, assuming s/he has already reviewed the case. (1) If it is known that he will take over management of the patient's condition before he sees the patient I instruct them to bill transfer of care. (2) If it is
not known, before s/he enters the room or by the end of the encounter, then they can bill a consult if all consult requirements are met (3 Rs). (3) If it is
not known before the provider begins the encounter and decided after consultation I instruct them to document it to make clear a consult was necessary before decision could be made, also document the three Rs and bill a consult.
Our external auditor disagrees with me. She insists it is a transfer of care even if the decision can not be made until after the encounter has concluded. So, there are varying opinions. I will attend a WPS conference next month and this is at the top of my list for Q&A clarification.
Seems to me, I developed my opinion based on something I read from either AAPC, WPS, AHIMA or Medicare. I was googling, trying to find my way back to that source when I stumbled upon this thread.
