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Thread: 2010 proposed rule and consults

  1. #1
    Join Date
    Apr 2007

    Default 2010 proposed rule and consults

    AAPC: Back to School
    I am the first one to admit I will be happy to see consults go away. I will not be happy to lose the money though.

    Has anyones accounting department done the analysis of the impact it will have on the bottom line? I was putting together a newsletter for my facility and I started doing the comparisons. I got about half sick.

    Outpatient is not too bad, at least there are 5 code levels to crosswalk to. It is still a hit though. Currently medicare approves $ 124.79 for a 99243 that would be equal to a 99203 if they are a new patient, which they approve $ 91.97 for, or a 99214 if they are established which they approve $ 92.33. Not good but not near as bad as inpatient.

    Inpatient consults would crosswalk to subsequent care codes. This means that 99255, 99254, and 99253 would all be coded as 99233. Currenlty we get $ 201.97 for 99255, $ 165.55 for 99254, and $ 114.69 for 99253. 99233 is $ 95.58.

    I haven't spoken to our accounting department, yet, and I really don't look forward to hearing what they have to say. I just wanted to see if anyone else had looked at the impact this will have. Are your offices submitting comments to CMS on this?

    I have several specialists and consults are the bulk of their E/M services. Ouch is all I can say at the moment.

    Laura, CPC, CEMC

  2. #2
    Join Date
    Apr 2007
    Greeley, Colorado


    Laura - your post has definately sparked my interest. I thought I read somewhere that the differnce in reimbursement for a consult vs new patient or subsequent hospital was going to be adjusted on the Medicare fee schedule "accordingly". I'll be darned if I can find where I read that, though. I would love to hear other's comments and concerns on this issue. I too will be jumping for joy once consult codes are gone with the exception of the impact that will have on the bottom line...
    Lisa Bledsoe, CPC, CPMA

  3. #3
    Join Date
    Apr 2007


    They state that "Resulting savings would be redistributed to increase payments for the existing E/M services".

    To me the kicker is they don't say how much and they don't actually state they are going to increase above the current rate. My fear is instead of increasing, they just won't cut those rates any further and leave them as they are.

    I guess we will see....

    Laura, CPC, CEMC

  4. #4
    Join Date
    Apr 2007
    Greeley, Colorado


    Good point.
    Lisa Bledsoe, CPC, CPMA

  5. #5
    Join Date
    Apr 2007
    Charleston, South Carolina


    If you go to the end of the proposed rule, its lists the "propsed" RVUs for physicians for 2010 by CPT. The conversion factor is proposed at $28.3208 per RVU, so mulitply; or look at the RUVs for this year (2009) and compare. I am traveling and can't do this right now, but hope this info helps.
    Machelle Morningstar, CPC, COC, CEMC, COSC
    AHIMA Approved ICD-10-CM/PCS Trainer

  6. #6
    Join Date
    Apr 2007

    Default Info from the Federal Register

    I actually sat here and read thru this, fun. This is an interesting twist. They are saying for inpatient consults they are going to create a modifier for the primary admitting doctor to use with their admit and let providers who would normally use consult codes use the admit codes as well. This would mean more work for providers that routinely do 99251 & 99252, and of course it is still a pay cut for the other 3 inpatient consult codes down to admits.

    "If we adopt this
    proposal, then we will make
    corresponding changes to our
    regulations at § 410.78 and § 414.65. In
    addition, we will add the definition of
    these codes to the CMS Internet-Only
    Medicare Benefit Policy Manual, Pub.
    100–02, Chapter 15, Section 270 and the
    Medicare Claims Processing Manual,
    Pub. 100–04, Chapter 12, Section 190.
    Outside the context of telehealth
    services, physicians will bill an initial
    hospital care or initial nursing facility
    care code for their first visit during a
    patient’s admission to the hospital or
    nursing facility in lieu of the
    consultation codes these physicians
    may have previously reported. The
    initial visit in a skilled nursing facility
    and nursing facility must be furnished
    by a physician except as otherwise
    permitted as specified in § 483.40(c)(4).
    In the nursing facility setting, an NPP
    who is enrolled in the Medicare
    program, and who is not employed by
    the facility, may perform the initial visit
    when the State law permits this. (See
    this exception in the Internet-Only
    Medicare Claims Processing Manual,
    Pub. 100–04, chapter 12, § 30.6.13A).
    An NPP, who is enrolled in the
    Medicare program is permitted to report
    the initial hospital care visit or new
    patient office visit, as appropriate,
    under current Medicare policy. Because
    of an existing CPT coding rule and
    current Medicare payment policy
    regarding the admitting physician, we
    will create a modifier to identify the
    admitting physician of record for
    hospital inpatient and nursing facility
    admissions. For operational purposes,
    this modifier will distinguish the
    admitting physician of record who
    oversees the patient’s care from other
    physicians who may be furnishing
    specialty care. The admitting physician
    of record will be required to append the
    specific modifier to the initial hospital
    care or initial nursing facility care code
    which will identify him or her as the
    admitting physician of record who is
    overseeing the patient’s care.
    Subsequent care visits by all physicians
    and qualified NPPs will be reported as
    subsequent hospital care codes and
    subsequent nursing facility care codes.
    We believe the rationale for a
    differential payment for a consultation
    service is no longer supported because
    documentation requirements are now
    similar across all E/M services. To be
    consistent with OPPS policy, as noted
    above, we will pay only new and
    established office or other clinic visits
    under the PFS."

    Laura, CPC, CEMC

  7. #7
    Join Date
    Apr 2007


    can anybody share the crosswalk for hospital clinic visits. I will appreciate it.

    thank you

  8. #8


    Can someone post a link to the rule, please? Thanks.
    Dawson Ballard, Jr., CPC, CEMC, CPMA, CCS-P, CPC-P
    Compliance Auditor

  9. #9
    Join Date
    Apr 2007
    North Carolina


    Is this what you're looking for Dawson?

    Last edited by RebeccaWoodward*; 08-19-2009 at 07:09 AM.

  10. #10


    It is. Thanks so much!
    Dawson Ballard, Jr., CPC, CEMC, CPMA, CCS-P, CPC-P
    Compliance Auditor

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