New Medicare Consultation Policy

Earlier this year, the Academy had the opportunity to provide comments on Medicare's proposed consultation policy.  Despite this advocacy effort by the AAP and many other medical specialty societies, CMS decided to eliminate use of the consultation codes in the Medicare program starting January 1, 2010.  In response to this decision, the Academy has developed a position paper which summarizes the Academy's comments submitted to CMS toward advocating for reconsideration of the Medicare policy.  It is important to note that:

  • Consultation codes are not being deleted from CPT nomenclature
  • Consultation codes will remain on the RBRVS fee schedule with their established values
  • This is a Medicare payment policy and will not necessarily be adopted by other payers. However, if non-Medicare payers do choose to adopt this policy, it is imperative that they also make the budgetary accommodations as have been done in the Medicare program. The Medicare funds saved in not paying for consultations have been used to increase the 2010 RBRVS relative value units for other evaluation and management (E/M) codes, including the new and established office visit codes (99201-99215) and the initial hospital care codes (99221-99223). Non-Medicare payers that follow the Medicare consultation policy must also utilize the higher RVUs for these non-consultation E/M codes.

In response to the AAP letter advocating for continued payment for consultation codes (CPT codes 99241-99245; 99251-99255) several carriers will continue to pay separately for the codes under their commercial plans: Aetna, CIGNA, Coventry, Harvard Pilgrim Health Care, Humana and UnitedHealthcare. The Centers for Medicare and Medicaid Services (CMS) eliminated payment for the consultation codes under Medicare effective January 1; however, private payers are urged to pay for the consultation codes. The listing of carrier responses and the AAP letter are posted on the PPA Web page (member login required).
For more information, visit the AAP Coding & RBRVS Web page or contact the AAP Coding Hotline at aapcodinghotline@aap.org.