You have seen consultation codes mentioned in passing in the level-selection and hospitalist chapters; this chapter is where they get the full treatment, so if you came here from one of those cross-references, this is the complete picture.

Two practical notes on attribution
First, even when a payer does not honor consultation codes and you bill an office or hospital E/M instead, many employers still attribute the wRVUs of the service to you for productivity, so coding the correct level matters to your numbers regardless of what the payer ultimately pays. Second, for office visits with a longitudinal patient, remember that an eligible E/M can also carry G2211, adding about 0.33 wRVUs; consultations and one-time visits do not qualify, but an established relationship does.

A thoughtful consultation, reviewing the records, examining the patient fresh, writing a real opinion back to a colleague, is some of the most cognitively demanding work in medicine, and the codes that recognize it are worth understanding. Consultation codes (CPT 99241–99245 for outpatient, 99251–99255 for inpatient) have a complicated status in modern billing. Medicare eliminated payment for them effective January 1, 2010, and instructed physicians to substitute standard E/M codes in their place. Most commercial payers still recognize and pay consultation codes. Understanding this split is essential for any specialist who sees referred patients.

The Three Requirements for a Consultation

For the consultation code to apply, for commercial payers that recognize it, three elements must be present:

1. Request: Another physician or qualified health professional requested the consultation. This request should be documented, typically a referral note, order, or documented phone/electronic communication in the record.

2. Rendering service: You performed the consultation and documented it appropriately, with an E/M evaluation supporting the level billed under the consultation code range.

3. Report back: You communicated your findings and recommendations back to the requesting physician. This can be a formal written consultation note, a letter, or a documented message. It cannot be omitted.

If any of these three elements is missing, the encounter cannot be billed as a consultation, it defaults to a standard new or established patient E/M.

Medicare's Approach: Use Standard E/M Codes

For Medicare patients, what would have been billed as a consultation is billed as a new patient office visit (99202–99205) if it is the first visit, or an established patient visit (99212–99215) if the patient is established. The E/M level is determined by MDM or time, exactly as for any other office visit.

To be precise about the values: new-patient office codes carry higher work RVUs than the established-patient code at the same level, not lower. For example 99204 (new, level 4) is 3.00 wRVUs versus 99214 (established, level 4) at 1.92; 99203 is 1.60 versus 99213 at 1.30. The new-patient work is valued higher because of the added effort of a first encounter. So the rule to remember is: same level, new patient pays more, which is exactly why the new-versus-established determination is worth getting right.

The Outpatient Consultation Code Levels

Outpatient consultation codes follow the same MDM-or-time logic as standard E/M codes since the 2023 revisions aligned them with the 2021 framework. Note that 99241 was deleted in 2023, paralleling the deletion of 99201:

CPTMDM LevelTime Threshold
99242Straightforward20 min
99243Low30 min
99244Moderate40 min
99245High55 min

For commercial payers that recognize these codes, the moderate and high consultation levels reimburse at or above the equivalent new patient codes, which is why specialists with heavy commercial referral volume should not default to new patient E/M codes for everything.

Inpatient Consultations

Inpatient consultation codes (99251–99255) follow the same three-element rule, request, render, report back, for commercial payers. For Medicare inpatients, the substitution is the initial hospital or observation care codes (99221–99223). The level of these codes, like all E/M codes post-2021, is based on MDM or time.

Practical check for specialists
If a significant portion of your patients are commercially insured and are referred to you for specialist opinions, verify that your billing team is using consultation codes where appropriate. The revenue difference per visit is modest, but across a high-volume referral practice it adds up, and it also ensures the referring physician receives the formal report that the consultation code implies.

Telehealth Consultations

Consultation codes can be used for telehealth services when the same three requirements are met and the clinical evaluation supports the level billed. The standard telehealth documentation requirements apply (Modifier 95 or 93 depending on the modality), and the payer must cover telehealth consultations, which varies significantly by payer and state.

The Same Referral, Two Payers

A subspecialty wrinkle on "new" vs "established"
The three-year rule keys off same specialty and subspecialty, and Medicare actually distinguishes specialties by taxonomy. That has a useful consequence: if a patient saw a colleague in your group who has a different taxonomy designation, you may still be able to code a new-patient visit even though a partner saw them recently. A concrete case: a patient seen by a general orthopaedic surgeon in the group, then referred to the sports-medicine orthopaedic surgeon, can sometimes be a new patient to the sports specialist if the taxonomies differ. Confirm how your group's providers are enrolled before relying on this, but it is a legitimate distinction, not a loophole.

A cardiologist sees a patient referred by their primary care physician for evaluation of palpitations, with a clear request for opinion and a report back to the referring physician. For a commercial payer that still recognizes consultation codes, this is reported as an office consultation. For Medicare, which stopped recognizing consult codes, the identical encounter is reported as a standard new or established office visit instead. Same work, same documentation, different code depending on the payer. The practical discipline is knowing which of your payers still accept consults and coding each accordingly, rather than defaulting to one habit for everyone.

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