I'd love to be able to give you some great documentation, but I can't seem to dig up anything that specifically addresses this--and I'm not 100% sure I have all the information I need to make a clear call.
How did the first encounter (99231) come about? Was the physician called for their advice or opinion? Why wasn't a consult done the first day? Is this actually a transfer of care? What was the patient seen for? Is there a documented request for the consult (and is it written in a way that it applies to the subsequent date)? What was the content of the 99231 note?
[A transfer of care occurs when a physician or qualified NPP requests that another physician or qualified NPP take over the responsibility for managing the patientsâ€™ complete care for the condition and does not expect to continue treating or caring for the patient for that condition.
When this transfer is arranged, the requesting physician or qualified NPP is not asking for an opinion or advice to personally treat this patient and is not expecting to continue treating the patient for the condition. The receiving physician or qualified NPP shall document this transfer of the patientâ€™s care, to his/her service, in the patientâ€™s medical record or plan of care.
In a transfer of care the receiving physician or qualified NPP would report the appropriate new or established patient visit code according to the place of service and level of service performed and shall not report a consultation service.]
The "rule" for an initial consultation is that it must be reported only once per patient per facility admission. It doesn't say it must be the FIRST encounter with the patient, though if this is how the physician came to know the patient it usually is.
[In the hospital setting, following the initial consultation service, the Subsequent Hospital Care codes (99231 â€“ 99233) shall be reported for additional follow-up visits.]
Maybe with a little clarification I can direct you better.
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