Tags: coding/cpt consultation inpatient em

Overview

Consultation codes are reported when a physician or other qualified health care professional (QHP) is asked by another provider to render an opinion or advice regarding evaluation/management of a specific clinical problem — not to assume ongoing management of the patient.

Inpatient/Observation Consultation Codes (2026)

CPTMDM LevelTotal Time (date of encounter)
99252Straightforward≥35 min
99253Low≥45 min
99254Moderate≥60 min
99255High≥80 min

99251 Deleted

99251 (straightforward, formerly the lowest level) was deleted effective 1/1/2023 as part of the E/M revision. Code selection now starts at 99252.

Medicare Does Not Pay

Medicare has not recognized consultation codes (99241–99245, 99251–99255) since 1/1/2010.1 Bill initial hospital/observation care (99221–99223) or subsequent hospital care (99231–99233) instead, per payer crosswalk.

Consultation Requirements (Non-Medicare)

The 3 R’s

  1. Request: Written or verbal request from another provider, documented in the chart
  2. Render: Provide opinion/recommendations
  3. Report: Written communication back to the requesting provider

Documentation Elements

ElementRequirement
RequestWho requested the consult, and why
OpinionClear assessment and recommendations
ReportDocumented communication back to requesting provider

When to Use Consult vs. E/M

ScenarioCode Type
Transfer of CareInitial Hospital/Observation Care
Opinion OnlyConsultation (if payer recognizes)
Co-ManagementSubsequent Hospital Care
Medicare PatientInitial/Subsequent Hospital Care (never consult)

Emergency Room Consults

Consultations can be billed int he emergency room but specialists typically must use Emergency Department visit codes (99281-99285) rather than traditional consultation codes. Most insurance payers and Medicare do not accept separate outpatient or inpatient consultation codes for patients evaluated and discharged in the emergency room. Instae, billing rules require specific guidelines to be met.

Payer-Specific Recognition — Verify Before Billing

PayerConsultation Codes Recognized?Notes
MedicareNo (since 2010)Use 99221–99223 or 99231–992331
Wisconsin Medicaid (BadgerCare Plus)Historically yes, at reduced rate80% of standard fee schedule effective 5/1/2012;2 confirm current ForwardHealth fee schedule hasn’t since aligned with Medicare
UnitedHealthcare (commercial/exchange)NoDenies 99242–99245 and 99252–99255; bill appropriate E/M3
CignaNo (since 10/19/2019)Denies consult codes; resubmit with non-consultative E/M4
BCBS plans (general trend)Increasingly noSeveral BCBS plans (e.g., BCBS NM 9/1/2024) have dropped reimbursement;5 confirm current BCBS of WI policy directly — not yet verified for this payer
UMRNot confirmedUMR is a UnitedHealth Group TPA; plan-level policy may follow UHC’s stance above — verify per specific group plan
AetnaNot confirmedNo current policy verified in this pass — check Aetna’s Clinical Payment/Coding Policy before billing

Practical Reality

The commercial-payer trend since ~2019–2024 has been near-universal alignment with Medicare’s non-recognition policy. When a payer isn’t listed above with a confirmed source, default to verifying rather than assuming the consult code will pay.

Modifiers

ModifierUseContext
-AIPrincipal physician of recordAppended to the admitting physician’s initial hospital/observation care code (99221–99223) — not to a consultation code itself — to distinguish the admitting provider from other physicians billing the same initial-care code range for the same date

Flagging an Error From Your Original Note

Modifier -XS is an NCCI-associated modifier meaning “Separate Structure” — it’s used to bypass a procedure-to-procedure edit when two procedures are performed on distinct organs/structures. It doesn’t have a standard application to E/M consultation coding. If you were thinking of a modifier for a same-day, separately identifiable E/M service, -25 or -57 (decision for surgery) are the ones that actually apply here. Let me know if you want a modifier reference table built out for those instead.

00 Inpatient ProFee Coding MOC Inpatient E&M Codes Inpatient Modifiers


📚 Sources

1. Centers for Medicare & Medicaid Services, *Evaluation and Management Services Guide*, MLN Booklet MLN006764, rev. 2021; consistently cited in payer policy bulletins (e.g., AmeriHealth Claim Payment Policy MA00.049b). 2. Wisconsin Department of Health Services, ForwardHealth Update No. 2012-14, "Change to Reimbursement for Consultation Services," effective 5/1/2012. 3. UnitedHealthcare Commercial and Individual Exchange Reimbursement Policy, "Consultation Services Policy, Professional," Policy No. 2025R0129A. 4. Cigna payment policy update, effective for claims processed on/after 10/19/2019, as reported by AAFP/FPM (Kent Moore, Aug. 27, 2019). 5. Blue Cross and Blue Shield of New Mexico, Clinical Payment and Coding Policy CPCP024, "Evaluation and Management Coding," effective 9/1/2024.