The elimination of consultation codes from the Medicare National Bank just opened up a massive growth opportunity for physician consulting services and I don't think anyone is paying attention. Well, here at the Happy Hospitalist, if you offer physician consulting services in the hosiptal, you just hit the economic gold mine. And Happy is here to tell you why. How you ask?
You see, when Medicare got rid of consult codes (99251, 99252, 99253, 99254, 99255), they removed the requirement that the consultant must be asked to see the patient with a written request documented in the chart. What does that mean? As a consultant, under the old consult rules, you could only bill Medicare for seeing a patient if you were asked to see them and that request was documented in the record.
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Other useful information is available at my EHR Resource Center. What are the new consult rules? When Medicare got rid of consult codes and replaced all initial hospital evaluations with the initial hospital visit/admission codes 99221, 99222 or 99223 (99223) or the critical care codes 99291 and 99292 they removed all requirements that the physician consulting service be requested to see the patient first.
None of these listed codes above require documentation in the chart for a request for consultation. What does that mean for my consulting specialist protocol? I think it means physician consulting just became a self referring gold mine. For physicians to get paid for a consult and not be accused of fraud, they had to be asked to see the patient.
I wouldn't consult a specialist for every case of COPD or pneumonia, even if they had a specialist in the lung clinic. I wouldn't consult a cardiologist for every case of CHF or chest pain, even if they had a cardiologist in the heart clinic. If I consulted medical subspecialists everytime a clinic patient of theirs with pneumonia or COPD or CHF or uncontrolled diabetes patient got admitted, I would offer nothing of value than dictating a discharge summary.
Any high school student or EMR system can be trained to do that and do it well. My value comes in my medical decision making and study after study proves hospitalists reduce length of stay without any drop off in quality. What is a hospitalist? We are efficiency generators. We are hospitalist efficiency generators.
The implications of these new rules are huge and I don't think anyone, including CMS, is paying attention. Here's how I interpret the new Medicare rules. If you are a physician consulting service and you have a previous relationship in any way with the hospitalist's patient, you could potentially sign yourself onto the case and start evaluating the patient every day and bill a charge every day, even if you weren't asked to see the patient.
That's because in order to get paid for your visit, you no longer have to be asked to see them. You won't be violating any HIPAA regulations since you already have a working relationship with the patient. You saw the patient ten years ago for a five minute office consult for atypical chest pain, and now they have a suspected smoking induced coronary blockage? Just sign yourself on the case before the other cardiologist group has a chance to get involved. The patient's here for pneumonia and you're a surgeon who saw them eight years ago for a below the knee amputation? Just sign yourself onto the case and make a few dollars offering your medical opinion, about nothing that matters. It's all necessary, because it's always necessary.
Don't be late. It's going to be a competition for E/M crumbs. If you're making less money on each visit you make with declining reimbursement, just hire a troop of data gathering nurses to scour the hospital patient data base every morning at 7 am and have that list of patients cross referenced with your thirty years of office records. Ah, the beauty of the government's push for EMR. Now physician offices can hunt down any patient they've ever seen and get involved in their hospital care, no matter what the reason. The reason doesn't matter anymore. In fact, Medicare said you no longer need to be asked.
Just playing by the rules. That's how it's done. Right?
Every time you find a match with your government mandated EMR , you have just found yourself a consult, to help pay for the EMR, whether your services meet medical necessity muster. This is Medicare, where all care is medically necessary. Heck, if I'm a surgeon, and it's a slow day at the office, I might even consider rounding on a couple dozen decades old lap choles just to collect a grand or two in E/M codes for hospital based medicine.
What are you physician consulting docs waiting for? Perhaps with Medicare Doomsday and the 23% physician payment cut just weeks away, it's time for physicians to take advantage of another of the many unintended consequences of health care reform and flood the Medicare system with unnecessary but necessary evaluation and management services. As a hospitalist, I'm even thinking about hiring a few homeless folk to cross reference the active hospital patient list with every previous patient Happy's hospital group has ever seen. Though, I might need a little help from our medical practice management software organization to get the job done.
What are you waiting for doc? Get out there a see some patients.
