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Otolaryngology Coding Alert

Get the Lowdown on CMS Transfer-of-Care Regs

Don't let narrow interpretations stop you from using 99241-99245 for tube candidates You can confidently code consultations for probable surgical patients -- but only if you can interpret what Medicare means by the simple phrase -complete care for the condition.-

Otolaryngologists are reeling from phrases that Medicare added to its consultation wording. The transfer-of- care rule, for example, is -a change to which we are continuing to object,- says Stephen R. Levinson, MD, managing member of ASA, LLC, author of Practical E/M: Documentation & Coding Solutions for Quality Patient Care; and a Fellow of the American Academy of Otolaryngology -- Head and Neck Surgery (AAO-HNS).

Rather than be subjected to the various interpretations milling about consultation coding, get the facts yourself.

Understand the Fury-Causing Words The new guideline that scares physicians says, -Payment for a consultation service shall be made regardless of treatment initiation unless a transfer of care occurs.- In language introduced to the Medicare Claims Processing Manual section 30.6.10 -- Consultation Services on Jan. 1, 2006, in Transmittal #788, CMS then describes:

-A transfer of care occurs when a physician - requests that another physician - take over the responsibility for managing the patient's 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 - 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- [emphasis added].

Fall out: The reference to -complete care for the condition- has led to numerous interpretations of consultation codes- applicability. -It is unclear whether [the phrase] means that physicians performing consultations are precluded from billing for an initial consultation if any transfer of care is involved,- says an Oct. 26, 2006, AMA letter to CMS Acting Administrator Leslie Norwalk, Esq, CMS, in which numerous associations and societies including the AAO-HNS request assistance in revising the Medicare consultation policy. See It From CMS, AMA Perspectives Argument 1: Interpreting the phrase narrowly -- to mean no consult when any transfer of care occurs -- would make a consultation a rare occurrence. If the transfer-of-care verbiage -were the only text in the transmittal, it would be reasonable to conclude that many visits that have been considered consultations would not qualify because the requesting physician anticipates that the consultant will be primarily responsible for handling treatment of the problem,- writes David Glaser, an attorney with Fredrikson & Byron in the article -New Guidance Related to the Consultations Codes- published in Fredrikson & Byron's Health Law Flash Focus, January 2006.

Argument 2: The AMA letter furthers the idea that a tight interpretation of transfer of care is inappropriate. -We understand that the CPT Editorial Panel is [...]


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