To me, pre-op exams usually meet the criteria for a consult. You have the three R's (request, rendereing of service, and report). You are getting the request from the surgeon. You are rendering the exam/testing, etc., and then you are sending a written report of your findings back to the surgeon. This meets the criteria for a consult. If the three R's are not met, then I agree you would report a problem-oriented E/M code (99201-99215) instead.
Medicare does not accept the consult codes anymore, so for pre-op exams on Medicare patients, you have to report a problem-oriented E/M code (99201-99215).
This represents my opinion of how we do these types of encounters at my sites.