Admission Date, Initial Hospital Service Date: Two in the Same?
By William P. Galvin, CPC
Call on 99221-99223
Codes 99221-99223 often are referred to casually as “admission codes.” In fact, these codes do not describe an admission service, but rather the initial evaluation and management (E/M) of the patient in the hospital. CPT® guidelines, found within the text preceding the Hospital Inpatient Services/Initial Hospital Care codes, specify: “The following codes [99221-99223] are used to report the first hospital inpatient encounter with the patient by the admitting physician” [emphasis added].
There is no requirement within CPT®—or within the Centers for Medicare & Medicaid Services (CMS) Medicare policy—indicating an initial service be reported only on the admission date. You would report 99221-99223, as appropriate to the documented level of service, for the initial hospital service, regardless of whether the initial service occurs on the same day as the admission.
Several Medicare carriers post advice that supports this coding. For example, WPS Medicare—Part B carrier in Illinois, Michigan, Minnesota and Wisconsin—offers the following Q&A examples on its web page:
“Question: When the physician provides a direct admit from the office, can we bill an initial hospital visit even though the physician does not go to the hospital on that day?
“Answer: No. An initial hospital visit code is the first encounter with the patient as an inpatient in the hospital. Billing an initial hospital visit procedure code is not appropriate if the physician does not see the patient in the hospital. The physician would bill the office visit and then bill the initial visit code when he/she sees the patient in the hospital. If the physician sees the patient in the hospital on the same day as a visit in another site of service, only the initial hospital visit may be billed.
“Question: The patient was admitted to the hospital on the 10th, but the Admitting Physician did not see the patient until the 11th. Should the Admitting Physician bill the initial visit on the 10th or 11th?
“Answer: The admitting physician bills the initial hospital visit the first time he/she sees the patient in the hospital. You can only bill the initial visit on the day it was performed — the 11th.
“Question: The Admitting Physician admitted the patient on the 10th and saw them briefly. I performed the H&P on the 11th. Can I bill a subsequent code on the 10th and the hospital admission on the 11th?
“Answer: The initial hospital visit procedure codes are used the first time the admitting physician sees the patient in the hospital. In the example, the initial visit is on the 10th. Choose the procedure code based on the documentation. The service on the 11th is a subsequent hospital visit.
“Note that the same rules apply to teaching physicians, even when a resident sees the patient on a previous day. For example, a history and physical exam (H&P) is performed by a resident on the 15th at 11:30 p.m. The teaching physician physically sees the patient at 7:30 a.m. on the 16th. If the claim is filed under the teaching physician’s unique physician identification number (UPIN), the initial hospital code (99221-99223) would not be coded until the teaching physician physically saw the patient and incorporated the resident’s notes and documented their own notes accordingly (that is, on the 16th).”
William Galvin, CPC, is the compliance manager for The Cambridge Health Alliance in Massachusetts. In his 20-year career in the health care field, Bill says he has been fortunate to have worked with many great people in world class health care facilities in and around the greater Boston area. Bill received his CPC® in 2004.