1. A request for a doctor's opinion (i.e., a consultation), must be made by a qualified source (eg, another doctor, PA, social worker, etc. - there's a list in the CPT book under the guidelines on page 17)
2. The consulting doctor gives his opinion/advice, in a formal written report, back to the requesting source.
3. All of the above is documented in the patient's medical record.
As far as who to bill the (non-consultation) E/M under, that depends on the payer, and the circumstances surrounding the actual visit. If it's not Medicare, check your contracts to see if incident-to billing is even allowed (sometimes referred to as 'pass-through' billing with commercial payers) - there will likely be criteria that has to be met, if so.
If it is Medicare, then the only way to bill incident-to, is if:
A) the physician was physically in the building at the time services were rendered - as in, in the same office suite - not down the hall performing surgery, or in the cafeteria on the next floor, or out in the parking lot, etc.
B) it's an outpatient encounter - no incident-to is allowed for inpatient visits, and
C) The physician has already established a plan of care for the condition being evaluated - meaning, no new problems (acute conditions are immediate disqualifiers), and no new patients. It doesn't matter that he signed off... if all 3 of those conditions weren't met - you have to bill under the PA's #'s. Hope that helps!
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