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Can a FACEM who owns a GP clinic bill a 104 or telehealth equivalent when the GPs in the clinic ask for clinical input about cases they see?

Context

I am a specialist emergency physician (FACEM) and own a GP clinic. I am exploring how I might work clinically within the practice, either in a specialist capacity or otherwise, and want to ensure that any billing is fully compliant. The GPs in the clinic frequently seek my input regarding whether patients require ED referral or how I would approach particular clinical problems. I am interested in whether this type of consultation could be billed under Item 104 where appropriate, and whether there is a telehealth equivalent for this item.

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