FQHC Medicare New vs. Established Patient

The AMA (CPT) and CMS (Medicare) have different definitions for a New Patient:

AMA- “A new patient is one who has not received any professional services from the physician/qualified health care professional or another physician/qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice, within the last 3 years.”

CMS- “A new patient is one who has not received any professional medical or mental health services from any sites within the FQHC organization within the past three years.”

FQHC Medicare New vs Established Patient