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.