This is a free coding lecture about about observation CPT® billing codes 99234, 99235, 99236, 99217 and 99220. I am not a licensed coding expert but I do have many years of experience. Read at your own risk. I recommend you reference the AMA's CPT 2013 Standard Edition as the authority in CPT ®billing and coding. These are observation codes listed above. I have previously discussed my thoughts on various observation status scenarios. From the question gallery comes a question about observation status.
This is in regards to 99234-99236. There are 3 certified coders including myself who work in the physician building and then we have 1 certified coder who works in auditing. Now: Supposedly the auditor is telling us per our Medicare Carrier that the only way the physicians can bill 99234-99236 is when then patient comes in the day of and seen the day of. Let me explain. Patient comes into the hospital 3/1/09 late night, but the doctor doesn't see the patient until 3/2/09 and then discharges them 3/2/09. The auditor said the only thing the doctors can bill is 99217 because the Dr did NOT get into the hospital on 3/1/09.NOW... I disagree.... I feel the date of observation starts when the Dr comes in to see the patient on 3/2/09. Therefor as long as the patient was in there longer than 8 hours it is appropriate to bill the 99234-99236. Now comes the sad part.... we can not find anything in the AMA that agrees with us...so the hospital is listening to the Auditor and making all the doctors bill discharge only. Until we can present proof from the AMA or different from our medicare carrier we have to start billing all these OPO as 99217. Do you have anything in writing from the AMA regarding the codes 99234-99236? From what I can tell from your website you agree with what we have to say with the 99234-99236. I need your help!!!!!! Please email me if I have confused you... I am confused myself.
The only time physicians can can bill using the admit/discharge codes 99234, 99235 or 99236 is when the patient is seen by the physician on two separate and identifiable face-to-face E/M encounters on the same calendar day and these visits are separated by at least eight hours. CPT® codes 99234, 99235 and 99236 can be used for both inpatient and observation status patients. The important thing is that the physician sees the patient twice on the same calendar date and these visits are separated by at least eight hours.
It doesn't matter that the patient came in the prior calendar date. Since there was no face-to-face encounter with that evening admit order, no E/M code is submitted by the admitting doctor that evening. The only thing I would disagree with from the auditor is that if a patient was admitted on 3/1/09 and discharged on 3/2/09, but the only date the physician saw the patient was 3/2/09, if the physician does an H&P, I would bill the H&P because it generally pays more than the discharge. If the physician does an H&P on 3/2/09, they should get paid for an H&P for 3/2/09, even though the admission date is 3/1/09. You get paid for the work you do, on the date of service you provided it. The physician can't bill both a 99218-99220 and a 99217 because Medicare will only accept one E&M code on a calendar day of service. So I say pick the one that pays more, which is more likely the 99218-99220, or the 99221-99223 not the 99217 or the 99238/99239. Here is more information on how to handle non-billing non-physician providers (NPP) in these situations.
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