- A true consultation needs a request for opinion and a report back to the referring provider.
- For referred commercial patients with no planned follow-up, the consultation often pays more.
- Medicare wants new or established codes instead.
Medicare dropped them; commercial payers did not
Medicare eliminated payment for consultation codes effective January 1, 2010 and told physicians to substitute standard E/M codes. Most commercial payers still recognize and pay them, often above a new-patient visit. If you see referred patients, that split is real money, and a thoughtful consultation, reviewing the records, examining the patient fresh, and writing a real opinion back to a colleague, deserves the code that recognizes it.
The Three Requirements for a Consultation
For a payer that recognizes consultation codes, three elements must be present:
1. Request: another physician or qualified health professional asked for your opinion. Document the request: a referral note, an order, or a recorded phone or electronic message.
2. Rendering service: you performed and documented an evaluation that supports the level reported in the consultation range.
3. Report back: you sent your findings and recommendations to the requesting clinician as a written consultation note, letter, or documented message. This step cannot be skipped.
Missing any one of the three, the encounter is a standard new or established patient E/M. A transfer of care is not a consultation.
Medicare's Approach: Use Standard E/M Codes
For Medicare patients, report a new patient office visit (99202-99205) for a first encounter or an established patient visit (99212-99215) otherwise, leveled by MDM or time like any office visit.
Same level, new patient pays more, so whether a referred Medicare patient is new or established to your group is worth getting right; the three year rule that decides it, and the wRVU gap it protects, are in the MDM guide.
Quick answer version: Is CPT 99241 still a valid code?
The Outpatient Consultation Code Levels: 99242 to 99245
The 2023 revisions aligned outpatient consultation codes with the 2021 MDM-or-time framework and deleted 99241, paralleling the deletion of 99201:
| CPT | MDM Level | Time Threshold |
|---|---|---|
| 99242 | Straightforward | 20 min |
| 99243 | Low | 30 min |
| 99244 | Moderate | 40 min |
| 99245 | High | 55 min |
For commercial payers that recognize them, the moderate and high consultation levels pay at or above the equivalent new patient codes, so a specialist with heavy commercial referral volume should not default to new patient codes for everything.
Inpatient Consultations: 99252 to 99255
Inpatient consultation codes (99252-99255; 99251 was also deleted in 2023) follow the same request, render, report back rule for commercial payers. For Medicare inpatients, substitute initial hospital or observation care (99221-99223), leveled by MDM or time.
Telehealth Consultations
Consultation codes apply to telehealth when the same three requirements are met and the evaluation supports the level. The modifier and place of service follow the same rules as any telehealth visit, covered in the telehealth guide; what is specific to consultations is coverage, so confirm the payer pays for telehealth consultations, since that varies by payer and state.
The Same Referral, Two Payers
A cardiologist sees a patient referred by their primary care physician for palpitations, with a clear request for opinion and a report back. A commercial payer that recognizes consultation codes gets an office consultation. Medicare gets a standard new or established office visit for the identical encounter. Same work, same documentation, different code by payer, so know which of your payers accept consults and code each accordingly rather than defaulting to one habit for everyone.