Thanks Kristin for your response. So two things:
a). The Neurologist is not the admitting physician.
b). The way I am reading your response is that if a specialist is not an admitting physician, then there is NO way for this specialist to be reimbursed for the initial consultation service. In other words, unless you are an admitting physician, initial hospital care service codes 99221-99223 are simply not allowed for any physician. Unfortunately, this is counter to my understanding. Per CMS guidance "CLM104c12", which Chapter 12 of Medicare Claims Processing Manual, section 30.6.10 talks about Consultation Services and no way in this section is this limitation that CPT codes 99221-99223 is only intended for Admitting physician. Section 30.6.9.1 bullet G specifically talks about "Initial Hospital Care Visits by Two Different MDs or DOs when they are involved in same Admission". The guidance here is straight forward and it states "In the inpatient hospital setting all physicians (and qualified nonphysician ...) who perform an initial evaluation may bill the initial hospital care codes (99221-99223)". It further talks about modifier AI to identify the Principal physician of Record.
It is therefore my understanding that if a patient is admitted by a PCP, and the PCP then subsequently calls in consultation to a Neurologist and Cardiologist, the correct billing would be:
PCP - 99221-99223 with modifier AI
Neurologist - 99221-99223 without any modifier
Cardiologist - 99221 - 99223 without any modifier
Is my understanding incorrect?
Thanks.