If you are billing a consultation, it makes no difference whether the patient is new or established.
But to answer your question ... If the patient was seen within the last 3 years this is an established patient.
Finally .. I think your audit tool is a bit confused. The "with additional work-up" and "without additional work-up" apply to NEW PROBLEM (whether it's a new patient or an established patient). I would say you have a new problem because this is a traumatic injury. Even if this is the same ortho surgeon who repaired the hip previously, a traumatic injury is by definition a new problem.
F Tessa Bartels, CPC, CEMC
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