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Observation Billing With a Hospitalist

kernodle Posted Tue 19th of June, 2012 16:46:34 PM

A hospitalist admits a Medicare patient for Observation. On the following day the patient's PCP (from another practice) assumes care of the patient. The following a partner of the PCP (same Tax ID and specialty) sees the patient. On the 4th day the patient's PCP discharges the patient from Observation. Is this the correct way to bill?

Day 1 Hospitalist reports Initial Observation code.
Day 2 PCP reports Subsequent Observation code.
Day 3 PCP's partner reports Subsequent Observation code.
Day 4 PCP reports Discharge from Observation code.

SuperCoder Answered Tue 19th of June, 2012 17:42:26 PM

If the patient is converted to an inpatient status on the same day as the OBS admission, only an initial inpatient-care service is reported (e.g., 99222). For billing purposes, it is not necessary to redocument another history and physical exam (H&P), but hospitalists should write the new order for inpatient admission and update the OBS assessment with any relevant, new information to justify the need for conversion.

If the inpatient conversion occurs on the second calendar day of the OBS stay, the physician is allowed to report the initial observation care code (e.g., 99220) on day one, and the initial inpatient care code (e.g., 99223) on day two.4 Keep in mind that the physician must then meet the documentation guidelines for initial hospital care and redocument a complete H&P to support the reported code (e.g., 99223=a comprehensive H&P and high-complexity decision-making). The hospitalist is only permitted to reference the previous review of systems and histories, and must redocument the history of present illness, exam, and decision-making.

If the physician decides not to document to this level of detail in support of the initial hospital-care service, reporting a subsequent hospital-care code (99231-99233) is considered reasonable. The physician should not report the OBS discharge (99217).

kernodle Posted Tue 19th of June, 2012 18:44:52 PM

The patient was never admitted as an inpatient. He spent the 4 calendar dates in Observation. Can you readdress the question?

SuperCoder Answered Tue 19th of June, 2012 18:58:25 PM

Observation-care services typically do not exceed 24 hours and two calendar days. Observation care for more than 48 hours without inpatient admission is not considered medically necessary but might be payable after medical review. Should the OBS stay span more than two calendar days (as might be the case with “downgraded” hospitalizations), hospitalists should report established patient visit codes (99212-99215) for the calendar day(s) between the admission service (99218-99220) and the discharge service (99217).3 The physician must provide and document a face-to-face encounter on each date of service for which a claim was submitted.

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