How to Code Observation For Hospitalist Taking Over From Primary Care Doctor (Different Medicare Group).

I get a lot of questions sent to me on how to code specific circumstances.  I recently received the following question:  Love your site...I've got a quick question... I'm having problems understanding Medicare observation billing rules (no surprise) as it relates to hospitalists, especially those of us who share responsibility with the patient's primary care doctor. I work weekends only.  The rest of the week is covered by the PCP. What I'm confused about is this talk of 'attending of record' as regards billing. Does that mean if a patient is admitted to observation on Friday  and I see them and discharge them on Saturday that I can't bill for the discharge because they were admitted to another doc (not in my medicare billing group)? Thanks in advance!

Thanks for that great question.  It sounds like you've landed yourself a job as a weekendalist.  You might look into signing up to be a weekend nocturnist, the least likeable shifts that ever existed.  They should carry the greatest shift differential.  Your described circumstance occurs quite frequently for hospitalist groups that still allow themselves to be taken advantage of for the convenience of others, especially for  primary care physicians who have left the hospital from 5pm to 7am and all day Saturdays and Sundays and holidays but are more than available during normal business working hours.

Observation is considered outpatient care.  That means if the patient is admitted and discharged on different calendar days, the observation admission codes (99218-99220) should be used by the attending on record on the day of admission into observations status.  The primary care physician as the attending of record would bill this code.   If the patient is discharged (by the hospitalist)  the following calendar day on an observation admission,  the  only CPT® billing code that should be submitted is 99217, the code for an observation hospital discharge code.  This code is submitted by the attending of record.  Your question as I understand it is how can the hospitalist bill for the discharge if the primary care doctor is the attending?  I have discussed use the use of all CPT® admission codes at another discussion linked here. 

If the primary care physician admits the patient and you, as the hospitalist, who is not part of the same Medicare practice group as defined by your practice ID number, the solution, I believe, is quite simple.  Simply write an order to transfer the attending of record to your name, since the PCP is no longer involved in the patient's care, and then discharge the patient.    I am not a certified coding compliance expert, but this is what I would do and it makes perfect sense. Since you are the attending physician of record for discharge, bill the observation discharge code Make sure to see all my free CPT® lectures for evaluation and management (E/M) in addition to all my resources for hospitalists.    Good luck!


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