Do you mean for Inpatient or OutPt/OBSV? There is no New or Est patient rules for inpatient encounters.
Was he called in for a Consult?
If the patient is Medicare (another physician admitted), then your physician codes 99221-99223 for his inital inpatient evaluation. Medicare doesn't recognize consult codes
If the patient is not Medicare (or a payer who follows the Mcare consult rule), then your physician codes either as a consult with 99251-99255 or as a subsequent visit with 99231-99233
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