As a compliance officer and coder I will give my best in opinion.
Regardless if you are accepting cash patients or patients with a carrier that you will bill, you will always code your claims according to the dictation provided, no ifs ands or buts! So as long as you are doing this you are compliant with coding guidlines. If the provider is doing the consult and the pt meets all of the three componets listed in any of your consults as new or established then you will bill your consult and get paid. These consults require a face to face visit.
Your 99080 is for a special report that the physician completes and usually there is no face to face vist these could be forms such as insurance forms. Doc, does not see the patient.
Code 99080 is intended to be used when a physician fills out something other than a standard reporting form, such as paperwork related to the Family and Medical Leave Act. This code does not apply to the completion of routine forms, such as hospital-discharge summaries. Also note that it would not be appropriate to submit 99080 in conjunction with 99455 or 99456, which are the codes for work-related or medical disability evaluation services. The descriptors for these codes explicitly state that they include "completion of necessary documentation/certificates and reports."
So, if you dr is providing face to face visits then you are compliant with your consults, bill away. If provider is just providing documentation then bill your special report code 99080.
We have many attorneys that prepay at our clinics for their clients, no law against it, but we really advise of facilities against doing it because it can cause numerous credits and man powere to invest later down the line when/if we have to refund any overpayments.
Hope this helps.