E/M Coding Skill Sharpener:
Hospital Observation Services
E/M Coding Skill Sharpener: Hospital Observation Services
Follow 3 main rules
for correct coding
when reporting
99217-99220 &
99234-99236
E/M Coding Skill Sharpener: Hospital Observation Services
Rule 1 • Report 99218-99220 with 99217 if the
physician admits the patient to observation
and releases her on a different date of service.
• For stays lasting multiple days, you may
report one unit of 99218-99220 for the first
date of service
• For subsequent days you should report
established patient codes (99212-99215)
E/M Coding Skill Sharpener: Hospital Observation Services
What Medicare says..
When a patient is held in observation
for more than two calendar dates, the
physician must bill subsequent
services furnished before the date of
discharge using the outpatient/office
visit codes, but should not use the
subsequent hospital care codes since
the patient is not an inpatient of the
hospital.
E/M Coding Skill Sharpener: Hospital Observation Services
Examples
Scenario 1
An emergency department (ED) physician admits a
patient to observation status at 9 p.m. on one day, and
discharges him early the next day at 6 a.m.
Report
Code 99218-99220 (initial observation care level) for
the first calendar date and discharge code (99217) for
the second calendar date and include complete
documentation in discharge notes.
E/M Coding Skill Sharpener: Hospital Observation Services
Scenario 2
The physician admits the patient to
observation at 9 p.m. on Wednesday
and releases the patient at 6 a.m. on
Friday.
Report
Code 99218-99220 for the first day and 99217 for the discharge.
You may report 99212-99215 if the physician documents an E/M
service on Thursday.
E/M Coding Skill Sharpener: Hospital Observation Services
You cannot report 99212-99215 as a
separate service on the same date as
99217-99220
E/M Coding Skill Sharpener: Hospital Observation Services
Rule 2
For stays of fewer than eight hours when
the admission and discharge occur on
different dates of service, report 99218-
99220 only, without a discharge service.
For Medicare patients receiving fewer than eight hours of
observation care in the ED, many providers will rely on the ED
E&M codes (99281-99285) rather than 99218-99220
E/M Coding Skill Sharpener: Hospital Observation Services
Rule 3
For observation stays that take place within a
single DOS, you should report the
observation/inpatient hospital care E/M codes
99234-99236.
Do not report a separate discharge code with
99234-99236 because these codes include both
the admission and discharge in their definition.
E/M Coding Skill Sharpener: Hospital Observation Services
If the patient is discharged
on the same date as
admission to observation,
pay only the initial
observation care code
because that code represents
a full day of care.
E/M Coding Skill Sharpener: Hospital Observation Services
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