I do not see the fraudulent coding at all. CMS has decided that consulting services do not exist. If you read the release they submitted they indicated the reason for this was that based on results of audits there was rampant inappropriate billing of consultation services when the documentation does not support the service as a consult. They indicated that they had tried to educate provides on exactly what a consult was to be and how to communicate the nature of a consult and even gave the simple formula of the 3 Rs to follow. However after all of their efforts they felt that there was too much of a misunderstanding and therefor the designation of consultation service was dropped. The decision however came too late in the year for the codes to be deleted from the CPT book so they made a memo to inform the industry that CMS was labeling consultation codes invalid. There is no fraud involved with this. The system we work withing is constantly evolving and the authorities do reserve the right to implement and delete codes at any time. So I am not sure where you are seeing that it is fraudulent coding for us to follow updated directives from the regulating authorities in our industry. I am just curious how you see this.
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