This isn't acceptable to me...
My carriers guidance....
Question: Would a ''CC:'' to the referring physician at the end of the consultant’s progress note be sufficient to satisfy consultation requirements?
Answer: A “CC” at the end of the consultant’s note is the most minimal approach to providing a report back to the requesting physician. The consultant would be responsible in this case for clearly documenting in such a manner that the requesting physician can discern the expert opinion/plan the consultant is providing.
We cannot verify that CERT or a Recovery Audit Contractor would accept this. A more direct and clear notation/brief letter would be better and should stand up to review by any and all parties.
The cite for the report back to the requestor is from CMS Publication 100-4, the Medicare Claims Processing Manual, Ch 12, sect 30.6.10 which says: After the consultation is provided, the consultant shall prepare a written report of his/her findings and recommendations, which shall be provided to the referring physician.
The manual does not prescribe a single or specific method of accomplishing this. As the carrier, we would expect to be able to see some notation that an appropriate "report" of some kind had been sent back to the requesting physician to complete the loop (i.e. support that the consultation requirements have been appropriately fulfilled). We'd find any simple statement to that effect satisfactory as long as there truly is a corresponding formal process to get the appropriate report back to the requesting physician (which a letter clearly seems to accomplish). Additionally, we would expect the consultation note to clearly address the issue for which the patient was referred. Finally, we would expect there is clear communication between the physicians to express the intent of the requesting doctor, i.e. is a consultation being requested or is care of a particular diagnosis the patient has being transferred to the second doctor (which should not be billed as a consultation but rather as a new patient visit).
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