Interprofessional Internet Consultations

CMS recognizes and pays for six codes for interprofessional consults codes 99446–99449, 99451, 99452

These codes were updated in 2023. Codes 99446, 99447, 99448, 99449 and 99451 may now be performed by physicians and other qualified health care professionals. Because these codes are in the E/M section, clinicians with E/M in their scope of practice may provide them (physician assistants and advance practice nurses.) CMS specifically stated this in the 2025 Final Rule in the section discussing HCPCS codes for behavioral interprofessional consult codes G0547–G0549, G0550 and G0551.

These are not considered telehealth services. Why?

• They aren’t on either CPT’s or CMS’s list of telehealth services
• They do not use real-time, interactive, audio visual communication with the patient
• Here is an audit tool you can use for these services
• For Medicare, these services require informed consent.  Since the consulting physician is not seeing the patient, the requesting physician must obtain and document informed consent.

• Slides

Consulting without seeing the patient

These six codes describe assessment and management consultative service provided by phone, internet or electronic health record when the patient’s treating physician/ non-physician practitioner (NPP) requests an opinion and/or treatment advice of a consulting physician/NPP.  The consulting physician/NPP has specific specialty expertise to assist in the diagnosis and/or management of the patient, without a face-to-face visit.

These are all time-based codes.

• The first five are for use by the consulting physician or NPP.
• The sixth is for the use of the treating physician or NPP.

CPT^® rules for reporting interprofessional telephone/Internet Electronic Health Record Consultations by a consulting physician

• Treating physician/NP/PA requests the opinion and/or treatment advice of a physician with specific specialty expertise to assist in diagnosis or management of the patient’s problem without seeing the patient
• May be a new or established patient to the consultant, for a new or existing problem
• Consultant may not have had a face-to-face service with the patient in the last 14 days
• May not bill if review leads to a face-to-face service with the patient in the next 14 days
• Majority of the time must be medical consultative verbal or internet discussion (greater than 50%)
• For 99446, 99447, 99448, 99449, if greater than 50% is in data review and/or analysis, do not bill those codes; according to CPT^®, this doesn’t qualify
• 99451 may be billed if more than 50% of the 5-minute time is data review and/or analysis
• Do not report these codes more than once in a 7-day period
• Do not use for a transfer of care
• Written or verbal request should be documented in the patient’s medical record, including the reason for the consult
• According to CMS, these codes are payable in both a facility and non-facility setting

CPT^® rules for reporting interprofessional telephone/Internet Electronic Health Record Consultations by a treating physician or other qualified health care professional

• Code 99452 may be reported by a physician, NP, PA
• Use for time of 16-30 minutes in a service day preparing for the referral and/or communicating with the consultant
• May not be reported more than once in a 14-day period
• May report face-to-face prolonged care codes with this service if an E/M service is also provided and the time exceeds 30 minutes beyond the typical time
• If the patient is not present, may report non-face-to-face prolonged codes if the time spent in the day exceeds 30 minutes

What is the difference between CPT® codes 99446 and 99451?

Question:

I’ve been trying to figure out what the difference is between CPT^® codes 99446 and 99451.  I finally found this in re-reading your article.  Is this the only difference between these 2 codes?

• For 99446, 99447, 99448, 99449, if greater than 50% is in data review and/or analysis, do not bill those codes; according to CPT^®, this doesn’t qualify
• 99451 may be billed if more than 50% of the 5-minute time is data review and/or analysis

I’m quite certain that I’m going to spend hours trying to make these new codes understandable to the docs, just for them to say it’s too much trouble for too little payment.

Answer:

99446-99449 require verbal and written feedback. Over half of the time must be spent in this verbal/electronic feedback.

“The majority of the service time reported (greater than 50%) must be devoted to the medical consultative verbal or Internet discussion).”

99451 doesn’t require it, and can be billed if more than 50% of the 5 minutes is in data analysis.

That’s what I see as the difference.