Pamela Posted 4 month(s) ago
I recently read an article in the RACmonitor (12/7/2017) by Ronald Hirsch, MD, FACP, CHCQM, [i]Physician Billing for Observation: If you Don't Order it, You Can't Bill for It[/i]. In it he stated CMS Processing Manual states CMS will “pay for initial observation care billed by only the physician who ordered hospital outpatient observation services and was responsible for the patient during his/her observation care”. Does this mean that a physician from a group practice that writes an admission order in the middle of the night must be the one who does the face-to-face visit with the patient in order to bill the observation code? And, his partners in the group can’t see the patient and charge subsequent observation codes? For example, we have a group of employed hospitalists that are basically considered the same “physician” for billing purposes. When Doctor A (from the hospitalist group) is on call and admits a patient to observation via telephone at 200 a.m., the following day Dr. B (from the same hospitalist group) is on call and goes to see the patient face-to-face for the first time and bills the initial Observation code (99218-99220). Other hospitalists in the group may see the patient during the stay and bill subsequent Observation codes (992224-99226) or discharge code (99217). Can you help clear up this conundrum?
SuperCoder Posted 4 month(s) ago
Greetings from SuperCoder!
Visit should be face-to-face to bill the observation code. If Dr. A admits a patient to observation via telephone at 200 a.m., then Dr. A needs to see that patient face-to-face and complete the documentation. On the other hand, if Dr. B goes to see the patient face-to-face for the first time and prepares documentation, then Dr. B should bill initial Observation code.
Please feel free to write if you have any question.
Pamela Posted 3 month(s) ago
February 21, 2018
Re: Observation Care
Dear Ms. Schulman:
This email is in response to your inquiry First Coast Service Options, Inc. received on February 2, 2018. Your inquiry pertained to a request for clarification on billing for initial observation care.
Medicare guidelines states the physician supervising the care of the patient designated as observation status is the only physician who can report an initial observation care Current Procedural Terminology (CPT) code 99218-99220. Payment for an initial observation care code is for all the care rendered by the ordering physician on the date the patient’s observation services began. All other physicians who furnish consultations or additional evaluations or services while the patient is receiving hospital observation services must bill the appropriate outpatient service codes.
The current policy for initial observation care also applies to subsequent observation care. Payment for subsequent care code is for all the care rendered by the treating physician on the day(s) other than the initial or discharge date. All other physicians who furnish consultations or additional evaluations or services while the patient is receiving hospital outpatient observation services must bill the appropriate outpatient service codes. Please refer to the Medicare Claims Processing Manual Chapter 12 section 30.6.8 for more information pertaining to payment for hospital observation services and observation or inpatient care services including admission and discharge services.
I hope the information I have provided is helpful. If you should have any further questions or concerns, you may contact our Provider Contact Center at 1-866-454-9007.
Provider Relations Research Specialist
This is the response I received from FCSO, my MAC provider. I am not sure, but it sounds as though they are saying even if the admitting physician is a member of the same group and covering, the covering physicians can't use observation codes. How do you interpret this?
SuperCoder Posted 3 month(s) ago
The above documentation says that “subsequent care code is for all the care rendered by the treating physician on the day(s) other than the initial or discharge date.” It clearly means that initial observation care should be billed by the physician who sees the patient face-to-face for the first time and also writes discharge of the patient. Only admitting physician can bill initial observation and discharge. Others may bill subsequent care.
We hope this answers your question. Please feel free to write if you have any question.
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