ED Coding and Reimbursement Alert

Question: Think I'm having a mental block...if time is going to be a factor, and Medicare requires a minimum of 8 hours, doesn't that mean you can't use the "typical times" for a Medicare patient? Does anyone know how the times not listed with Observation codes will impact the Medicare 8 hour rule??

North Carolina Subscriber

Answer: You are mixing two different time standards together. The new observation code language regarding the typical time "the physician spends at the bedside and on the patient's hospital floor or unit." is a measurement of how much time the physician spends caring for the patient. Whereas the Medicare eight-hour rule is a measure of how long the patient spends in observation.

That being said, you can bill observation if the patient is in observation for less than 8 hours, but for Medicare patients, you cannot bill the observation same day admit and discharge codes. Per CMS; "When a patient receives observation care for less than 8 hours on the same calendar date, the Initial Observation Care, from CPT® code range 99218 - 99220, shall be reported by the physician. The Observation Care Discharge Service, CPT® code 99217, shall not be reported for this scenario."