Gina Martin, MSHS, PA-C

As of January 1, 2010, Centers for Medicare & Medicaid Services (CMS) eliminated all consultation codes with exception of the telehealth consultation G codes. Medicare did increase the RVUs for the following services: new and established office visits, initial hospital care, and initial nursing facility care. Third-party payers (insurance companies that are not Medicare/Medicaid) will continue to utilize the consultation codes. What does this mean for you?

In the outpatient setting: Patient encounters that would have previously been billed as a consultation code (CPT 99241-99245), should now be coded with the E/M codes 99201-99215. These visits are eligible for incident-to billing if all of the requirements for incident-to billing are met.
In the inpatient hospital and nursing facility setting: Providers who perform an initial evaluation and management may bill the initial hospital care codes (CPT 99221-99223) or nursing facility care codes (CPT 99304-99306). These visits may be billed as a shared visit under the supervising physician’s NPI number if all of the requirements for a shared visit are met. Please note that due to this change, multiple billing of the initial hospital and nursing home visit codes could occur during a patient’s stay and even in a single day.
For additional information, readers may reference the following websites:
AAPA Reimbursement


PSPA leaders recently received news from Tricia Marriott at AAPA that Aetna has changed their payment policy for services rendered by physician assistants, nurse practitioners, and nurse midwives. According to the March 2010 edition of Aetna OfficeLink Updates: Mid-Atlantic Region: “Beginning with June 1, 2010 dates of service, Aetna will pay mid-level practitioners at 85 percent of the contracted rates for covered professional services (consistent with the Centers of Medicare and Medicaid Services payment policy).” As part of this policy change, Aetna is asking that Physician Assistants be officially listed in their network provider directories.  Please contact your Aetna provider representative for the billing implications of this change in policy.


The Centers for Medicare and Medicaid Services (CMS) issued Transmittal #788 dated December 20, 2005, which states that a consultation may not be billed as a shared visit. Office and hospital evaluation and management services continue to be eligible for shared visit billing. A shared visit is when both a physician and a PA treat the same patient on the same day in the hospital/office setting. Medicare allows the work of both health care professional to be combined with the service billed at 100% under the supervising physician as long as the physician performs some face-to-face portion of the visit. The physician’s involvement must be documented on the patient’s chart. Be aware that under Medicare’s guidelines, shared visits in the office setting must first meet the “incident to” requirement, making the concept of an office-based shared visit nearly a moot point.
AAPA held discussions with CMS and had argued that consults should be included as eligible shared visit services.
Printed with permission, Michael Powe, AAPA Reimbursement Watch.