Subsequent Observation Care

In the instance that a patient is held in observation status for more than two calendar dates, the supervising physician should utilize a subsequent observation care CPT code (99224-99226). Physicians other than the supervising physician providing care to a patient designated as "observation status" should report subsequent observation care. According to the CPT codebook, 

“All levels of subsequent observation care include reviewing the medical record and reviewing the results of diagnostic studies and changes in the patient's status (i.e., changes in history, physical conditions, and response to management) since the last assessment.”

Observation Care Discharge Services 

Per CPT, Observation Care discharge day management CPT code 99217 "includes final examination of the patient, discussion of the hospital stay, instructions for continuing care and preparation of discharge records." 

Observation Care discharge services include all E/M services on the date of discharge from observation services and should only be reported if the discharge from observation status is on a date other than the date of initial Observation Care. 

Oxford follows CMS guidelines that physicians should not report an Observation Care discharge Service when the Observation Care is a minimum of 8 hours and less than 24 hours and the patient is discharged on the same calendar date.

Observation Care Admission and Discharge Services on Same Date 

Physicians who admit a patient to Observation Care for a minimum of 8 hours, but less than 24 hours and subsequently discharge on the same calendar date shall report an Observation or Inpatient Care Service (Including Admission and Discharge Services) CPT code (99234-99236).

In accordance with CMS' Claims Processing Manual, when reporting an observation care admission and discharge service CPT code (99234-99236) the medical record must include: 

 Documentation meeting the E/M requirements for history, examination and medical decision making; 

 Documentation stating the stay for hospital treatment or observation care status involves 8 hours but less than 24 hours; 

 Documentation identifying the billing physician was present and personally performed the services; and 

 Documentation identifying that the admission and discharge notes were written by the billing physician.

Observation Care Services During a Surgical Period 

Observation care codes are not separately reimbursable services when performed within the assigned global period as these codes are included in the global package.