CMS Will Soon Issue Consult Code Replacement Advice, According to Open Door Forum

Posted on 10. Feb, 2010 by Editor in Provider News

Plus: You can now download a list of all practitioners who can order/refer.

If you’ve been confused about how to report low-level hospital visits now that consult codes are gone, you aren’t alone. CMS intends to tackle this problem by issuing more specific guidance on the topic in the near future.

That’s according to a Feb. 2 CMS-sponsored Physicians, Nurses, and Allied Health Professionals Open Door Forum, where one practice asked the CMS reps when the agency plans to issue instructions on how to report initial hospital visits when the documentation doesn’t meet the criteria for the lowest level visit, a 99221.

CMS is currently working with the medical community to create such guidance, which will “hopefully be out shortly,” noted CMS’s Whitney May during the call.

One caller indicated that her MAC (WPS Medicare) instructed her to use the unlisted E/M code 99499 when the visit doesn’t meet the criteria of 99221 — but the MAC also said …

it would be inappropriate to report a subsequent care code prior to an initial care code.

That interpretation basically says “that if you don’t meet the initial care code, you have to bill unlisted, but the next day if you don’t meet the initial care code you still can’t bill a subsequent visit because you haven’t billed an initial hospital care code, so you have to bill another 99499,” the caller said. “I understand you’re working on creating guidance on this issue, but what do we do today?”

A CMS rep. advised the caller to follow local contractor guidance until CMS is able to issue a more detailed update. “We’ve been working closely with the medical community to try to develop very clear instructions for how to address this particular situation as well as some other questions that have come...

Tags: 99221, 99499, CMS, consult, E/M, eligible, initial care, MAC, non-physician practitioner, NPI, order, physician, refer, subsequent care