Need more info. Did he scrub in and perform any part of the surgery? or was he just standing by the OR table shouting questions at the surgeon? It might be that he can bill for a portion of the surgery. What did the op note say?
If it's truly a consult.....it depends on the status of patient. Inpatient status, use 99221-99223. Outpatient, 99201-99215, depending on if he's seen the patient before.
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