One of the common misconceptions with CPT is that the book is laid out by specialty. While certainly we can see lines drawn here and there for what would constitute a "typical" service within a specialty, almost any "qualified" physician can render service from anywhere within that coding system.
Point being, yes, Radiologists can submit EM codes. Normally we don't expect to see that, and payers may create undue problems, but it is more common that one would expect.
I would submit those codes according to the level reflected in the documentation. In order to make sure they're on the right track, I'd recommend 100% review for awhile. Once they're up and roling, just be sure you're communicating with the payer side and submitting all the CORRECT documentation those folks might request--including orders, referrals, requests and so on.
Keep in mind, if there is a request, the Rad. is submitting an opinion and a report back to the requesting source, then a consult code may be appropriate.
Hope this helps.
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