CMS to Change Coding for Consultations Beginning January 1, 2010
From the American College of Surgeons
Beginning January 1, 2010, the Centers for Medicare & Medicaid Service (CMS) will eliminate the use of all codes for inpatient and office/outpatient consultations that occur in various places of service, except for telehealth consultation G-codes, on a budget-neutral basis. To
compensate for this change, CMS will increase the work relative value units (RVUs) for new and established office visits, increase the work RVUs for initial hospital and initial nursing facility visits, and incorporate the increased use of these visits into practice expense and malpractice RVU calculations.
For inpatient consultations, physicians will bill an initial hospital care or initial nursing facility care code for their first visit during a patient's admission to the hospital or nursing facility. In lieu of outpatient consultation codes, physicians will bill either new or established patient office visit codes, depending on whether the patient has sought professional services at the practice within the last three years.
In our response to the proposed regulations, the American College of Surgeons (ACS) argued that CMS should also increase the bundled payments for postoperative visits occurring within a 10-day or 90-day global period. CMS agreed with this proposal and increased the payments for those services. Our consultants estimate the increases in the payments for these 10-day and 90-day global services due specifically to this change will result in more than $65 million of increased reimbursement for these procedures.
Furthermore, this change should eliminate the confusion over documentation for consultations vs. transfers of care that has resulted in so many surgeons losing payments when referring physicians do not adequately document the request for a consultation.
The ACS anticipates that most surgeons will do at least as well financially under these rules as under the previous system of consult codes because of the increase in work RVUs for office and hospital visits and the increases in RVUs for practice expense and medical liability. CMS
estimates the combined effect of these changes will be approximately +1% in 2010 for general surgeons. ACS regulatory staff believe that this may be a conservative estimate.
The ACS is continuing to review the rule in detail and is developing educational materials to help our members comply with these new requirements. Please e-mail Elizabeth Hoy, Assistant Director for Regulatory Affairs and Quality Improvement Programs, at ehoy@facs.org if you have further questions.