Change: December 15, 2009--Good news!

The consult change would seem to allow hospitalists to bill for post op care using the initial hospital care codes.  Here is a post by Seth Canterbury, published with his kind permission, about the topic.

I read it to allow everyone's initial inpatient visit to be billable as Initial Hospital care, regardless of whether or not the initial visit would or would not have met the definition of a consult as it used to appear in the manual, and regardless of whether their first inpatient evaluation takes place on the day of admission or a later date.

 From the change request:

“In the inpatient hospital setting and the nursing facility setting all physicians (and qualified nonphysician practitioners where permitted) who perform an initial evaluation may bill the initial hospital care codes (99221 – 99223) or…”

 They refer to the Initial Care codes being used by multiple providers for each provider’s “initial evaluation,” with no qualification that the service must be one the meets the definition of what used to be a consult. This means, according to my reading, initial transfer-of-care evaluations would be coded the same as initial request-for-opinion evaluations and coded as 99221-99223. They are both simply treated as “an initial evaluation.” Nowhere in the new language is any reference made to having to determine which initial evaluations constitute what used to be considered a consult vs. a transfer-of-care situation, and that we are then required to code transfer-of-care initial evaluations using Subs. Hosp. Visit codes.

 Here is the quote that most closely pertains to the question:

 “In the inpatient hospital setting and the nursing facility setting all physicians (and qualified nonphysicians where permitted) who perform an initial evaluation and management may bill the initial hospital care codes (99221 – 99223) or nursing facility care codes (99304-99306). As a result of this change, multiple billings of initial hospital and nursing home visit codes could occur even in a single day.” [emphasis mine]

 Saying that multiple Initial Care visits could occur “even in a single day” implies to me that the sentence up to that point assumed that the point had been made/assumed that multiple billings of Initial Care on different days was allowed, and that they just needed to go a step further and say that you will even have multiple initial care visits billed on the same day.

 So if a certain specialty doesn’t provider their “initial evaluation” until post-admission day 30, that’s when that service will bill 99221-99223, according to how I read these rules.

Below text from summer, 2009

The rise of hospitalist services in community hospitals has been swift in the US, and no one is happier than Surgeons.  Having a medicine specialist in the house means the surgeon can concentrate on surgery, and leave the management of the patient's medical problems to someone else.  And, as hospitalist physicians say, "You don't want the surgeons writing the insulin orders."  That may be true.

However, the first post op visit by the hospitalist group is not a consult, but a subsequent hospital visit.  The surgeon is not looking for an opinion, but is transferring the care of the patient to the hospitalist service for the medical  conditions.  Only a subsequent hospital service may be billed.  Here is the citation from the CMS manual:

I.  Surgeon’s Request That Another Physician Participate In Postoperative Care
If the surgeon asks a physician or qualified NPP who had been treating the patient
preoperatively or who had not seen the patient for a preoperative consultation to take
responsibility for the management of an aspect of the patient’s condition during the
postoperative period, the physician or qualified NPP may not bill a consultation because
the surgeon is not asking the physician or qualified NPP’s opinion or advice for the
surgeon’s use in treating the patient.  The physician or qualified NPP’s services would
constitute concurrent care and should be billed using the appropriate subsequent hospital
care codes in the hospital inpatient setting, subsequent NF care codes in the SNF/NF
setting or the appropriate office or other outpatient visit codes in the office or outpatient
settings.