New vs established

If a patient has seen a physician for an EMG ( non E/M service) only in the past year and is subsequently referred back to him for a consult, would the visit be treated as New or established?

face-face established

If the physician performed a face-face encounter (E/M or procedure) the patient is established if within 3 years.

Consults

If asked for a consult, and a Medicare patient, the patient is established outpatient.

New or established

If you look in the front of the CPT book and the Medicare Claims Processing Manual, they distinguish between reading a diagnostic test (reading an xray or EKG) versus a face to face contact with the patient. I assume the MD who performed the EMG had a face to face contact with the patient and did not just interpret the test.