CMS Issues Additional Information Regarding Consultations

(PYA Alert dated June 22, 2006)

The Centers for Medicare and Medicaid Services (CMS) caused a stir when they issued Transmittal 788 on December 20, 2005 regarding consultations.  The transmittal specifies documentation requirements for consultations as follows:

• A request for a consultation from an appropriate source and the need for consultation shall be documented by the consultant in the patient’s medical record and included in the requesting physician or qualified NPP’s plan of care in the patient’s medical record; and
• After the consultation is provided, the consultant shall prepare a written report of his/her findings and recommendations, which shall be provided to the referring physician.

Many of us struggled with verifying documentation of the request for consultation by the requesting physician.  Unless the medical record is shared between the requesting and consulting provider, this is not an easy task! 

Good news!!!  Things just got a little better!  The Physician Regulatory Issues Team (PRIT) issued the following information on April 12, 2006:

“Medicare does not expect the consulting physician to verify that the requesting physician has documented the consultation request in his/her patient's medical record.”

Keep in mind, the request must still be documented by the requesting provider, however, the burden of verifying that this has been done by the consulting provider is relieved.

For more information, please contact Maggie Mac at (800) 270-9629.

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