ED Coding and Reimbursement Alert

Say Goodbye to Original Per-Day Observation Codes

In one stroke, CPT^® is getting rid of its per-day observation codes — but not the concept of observation services.

What’s being deleted? CPT^® 2023 will delete the following codes:

• 99218 (Initial observation care, per day, for the evaluation and management of a patient which requires these 3 key components: A detailed or comprehensive history; A detailed or comprehensive examination; and Medical decision making that is straightforward or of low complexity…)
• 99219 (… A comprehensive history; A comprehensive examination; and Medical decision making of moderate complexity...)
• 99220 (… A comprehensive history; A comprehensive examination; and Medical decision making of high complexity...)

What should I do? CPT^® 2023 will include the following coding directive:

• “99218, 99219, 99220 have been deleted. To report initial observation care, new or established patient, see 99221, 99222, 99223.”

In addition to the above deletions, CPT^® also rids itself of 99217 (Observation care discharge day management…) in 2023. According to CPT^®, “99217 has been deleted. To report observation care discharge services, see 99238, 99239.”

Discharge Services Moved Under 99238, 99239

Reporting discharge services will be different next year, as CPT^® created descriptors that will allow for one set of codes to be used for hospital inpatient or observation discharge day management.

What’s being deleted? CPT^® 2023 will delete the descriptors for the following codes:

• 99238 (Hospital discharge day management; 30 minutes or less)
• 99239 (… more than 30 minutes)

What’s being added? CPT^® 2023 will add these descriptors for the above-listed codes:

• 99238 (Hospital inpatient or observation discharge day management; 30 minutes or less on the date of the encounter)
• 99239 (… more than 30 minutes on the date of the encounter)

Impact: CPT^® is putting hospital inpatient or observation discharge day management services into the same code descriptors. You’ll use 99238 and 99239 for both these types of discharges.

CPT^® Gives Observation Big Revisions

CPT^® 2023 will retain its original initial per-day hospital care codes, but they will be vastly different and more inclusive of observation services.

What’s being deleted? CPT^® 2023 will delete the descriptors for the following codes:

• 99221 (Initial hospital care, per day, for the evaluation and management of a patient, which requires these 3 key components: A detailed or comprehensive history; A detailed or comprehensive examination; and Medical decision making that is straightforward or of low complexity...)
• 99222 (… A comprehensive history; A comprehensive examination; and Medical decision making of moderate complexity...)
• 99223 (… A comprehensive history; A comprehensive examination; and Medical decision making of high complexity…)

What’s being added? CPT^® 2023 will add these descriptors for the above-listed codes:

• 99221 (Initial hospital inpatient or observation care, per day, for the evaluation and management of a patient, which requires a medically appropriate history and/or examination and straightforward or low level medical decision making. When using total time on the date of the encounter for code selection, 40 minutes must be met or exceeded.)
• 99222 (Initial hospital inpatient or observation care, per day, for the evaluation and management of a patient, which requires a medically appropriate history and/ or examination and moderate level of medical decision making. When using total time on the date of the encounter for code selection, 55 minutes must be met or exceeded.)
• 99223 (Initial hospital inpatient or observation care, per day, for the evaluation and management of a patient, which requires a medically appropriate history and/or examination and high level of medical decision making. When using total time on the date of the encounter for code selection, 75 minutes must be met or exceeded.)

Impact: As the descriptors indicate, you will use 99221 through 99223 for all your multi-day hospital inpatient or observation services. For these services, you will choose from the revised 99238 or 99239 codes for discharge.

As with most of the 2023 E/M changes, Falbo says these changes should make things easier for coders and providers, “since there will be consistency in both outpatient and inpatient, where MDM [medical decision making] and time are the key factors.” There will also be “less administrative burden on meeting specific requirements for history and exam,” she says.

Remember: Unlike the ED E/M codes, the revised inpatient and observation code family can be chosen based on either MDM or time. Also, with the new requirement for only a medically appropriate history and physical exam, that pesky prior requirement for three out of three past, family, and social history (PFSH) will no longer hinder your observation code selections.

Get Ready for Single-Day Observation/Inpatient Code Combo

CPT^® 2023 will hold onto its single-day observation codes, but there are some changes. Much like the revisions of 99221 through 99223, these revisions will make the codes more inclusive.

What’s being deleted? CPT^® 2023 will delete the descriptors for the following codes:

• 99234 (Observation or inpatient hospital care, for the evaluation and management of a patient including admission and discharge on the same date, which requires these 3 key components: A detailed or comprehensive history; A detailed or comprehensive examination; and Medical decision making that is straightforward or of low complexity...)
• 99235 (… A comprehensive history; A comprehensive examination; and Medical decision making of moderate complexity...)
• 99236 (… A comprehensive history; A comprehensive examination; and Medical decision making of high complexity…)

What’s being added? CPT^® 2023 will add these descriptors for the above-listed codes:

• 99234 (Hospital inpatient or observation care, for the evaluation and management of a patient including admission and discharge on the same date, which requires a medically appropriate history and/or examination and straightforward or low level of medical decision making. When using total time on the date of the encounter for code selection, 45 minutes must be met or exceeded.)
• 99235 (Hospital inpatient or observation care, for the evaluation and management of a patient including admission and discharge on the same date, which requires a medically appropriate history and/or examination and moderate level of medical decision making. When using total time on the date of the encounter for code selection, 70 minutes must be met or exceeded.)
• 99236 (Hospital inpatient or observation care, for the evaluation and management of a patient including admission and discharge on the same date, which requires a medically appropriate history and/or examination and high level of medical decision making. When using total time on the date of the encounter for code selection, 85 minutes must be met or exceeded.)

Impact: As the descriptors indicate, 99234-99236 will be your one-stop shop for one-day hospital inpatient or observation care admission and discharge services.