I am not that familiar with the rules for billing consults, but I don't see where it indicates that it has to be a referral. The requirements are the same. So I guess my next question is are you the biller, or the coder? If you are not responsible for coding, and you are being told to bill a consult by the person responsible for the coding, I would go ahead and bill the consult. Unless you know that the code is truly inappropriate. If you are the coder, then I would pull out the patient chart, and the cpt book and see if it meets the criteria.
Michele