The short version
- A true curbside is informal — you can note your own reasoning, but you should not attribute advice to a named specialist in the chart [1].
- If the specialist's input is going to be named and quoted in the chart, the encounter has crossed into an eConsult — and should be documented and billed as one [2].
- Either way, the treating provider's medical decision-making stays their own.
Why documentation matters here
A curbside is, by definition, informal: the specialist does not see the patient, does not chart, and is not taking on the case. Courts have generally placed liability with the treating provider when curbsides go wrong, because the specialist's input was off-the-record [1].
That makes documentation a balancing act. Write enough to explain your reasoning; do not write so much that you make a no-strings specialist conversation look like a formal consult.
What to include in your note
- Your own assessment and plan, written in your voice. The plan is yours.
- The clinical reasoning, including the differential and what tipped you toward your decision.
- A general note that you discussed the case with a specialist colleague, if helpful — e.g. "discussed with a cardiology colleague; plan unchanged."
- Any patient counseling on next steps, follow-up, and red flags.
What to keep out
- The specialist's name and credentials (unless they have formally consulted and documented).
- Direct quotes attributed to the specialist as if they had evaluated the patient.
- Specific treatment instructions framed as the specialist's orders.
If any of those belong in the chart, you are no longer documenting a curbside — you are documenting an eConsult, and the workflow (consent, request, written reply, CPT 99451/99452) should follow [2].
A simple template
Assessment: [your differential and working diagnosis]
Reasoning: [why you landed here]
Discussion: Reviewed case with a specialist colleague;
no change to plan / minor adjustment to plan.
Plan: [your plan, in your voice]
Follow-up: [next steps, red flags, return precautions]When to switch to an eConsult
If the specialist's input is going to materially change the plan, if you want the specialist's reasoning on the record, or if you would otherwise have referred the patient out — run it as an eConsult instead. You get a written specialist report, the patient stays with you, and both sides can bill for the work [2][3]. See how an eConsult actually gets billed.
Frequently asked
Should I name the specialist I curbsided?
Generally no. Naming a specialist in the chart implies a formal consult, which exposes them to medical-legal risk for an off-the-record conversation. If the specialist's input belongs in the chart by name, run it as an eConsult with consent and documentation.
Can I quote a specialist's recommendation in my plan?
Not as a direct quote attributed to them. You can document your own reasoning, including that you discussed the case with a specialist colleague, but the plan should read as yours — because it is.
When does a curbside become an eConsult?
When the specialist's input is written, attributed, and lives in the chart — typically because the treating provider asked for it formally and the patient consented. At that point CPT 99451/99452 apply.
References
- 1.Cohen MS. The risk of the curbside consultation: peril of informal consultations. J Am Coll Surg. 2016;223(2):395–399.
- 2.American Medical Association. CPT Professional 2024 — Interprofessional Consultations (99446–99452). AMA, 2023. https://www.ama-assn.org/practice-management/cpt
- 3.Burden M, Sarcone E, Keniston A, et al. Prospective comparison of curbside versus formal consultations. J Hosp Med. 2013;8(1):31–35. https://pubmed.ncbi.nlm.nih.gov/23184866/
This article is for general educational purposes only and is not medical, legal, billing, or coding advice. Reimbursement rules and amounts vary by payer, state, and year — confirm with a qualified billing professional and your payer's current policy before acting on anything here.
See how Beam approaches this in practice
Beam runs same-day specialist consults documented in the chart. The fit depends on your setting and payer mix — happy to walk through it.