Pulmonology Coding Alert

Reader Question:

Hospital Observation Services

Question: Occasionally, a patient may be in observation for three days. But we are having trouble getting reimbursed for the second day. How should we code this?

Pennsylvania Subscriber

Answer: Pulmonologists should use 99217-99220 to report services provided to patients designated or admitted as "observation status" in the hospital. For you to report these codes, the patient does not need to be located in a specific observation area designated by the hospital.

Only the physician who admits the patient to observation and is responsible for the patient during his or her stay in observation may bill 99218-99220 (Initial observation care, per day, for the evaluation and management of a patient ...). Payment for a hospital initial observation code is for all the care rendered by the admitting physician on the date when the patient is admitted to observation status.

You should use 99217 (Observation care discharge day management ) for all services provided to the patient on the day of discharge from observation, provided this date is different from the date of the patient's admission to observation status.

CPT has no instructions on how to code for observation services provided on more than two dates of service. To report these services accurately, you should contact your local carrier and ask for a written or published medical policy bulletin for these coding and reporting guidelines. For example, the Pennsylvania Medicare carrier, HGSAdministrators, requires the healthcare provider to bill subsequent observation services using outpatient/office visit codes (99211-99215). The physician may not use the subsequent hospital care codes because the patient is not a hospital inpatient.

Alternatively, you could report the unlisted E/M service code 99499 (Unlisted evaluation and management service). In this case, you should submit the paper claim and include a written report of the services provided to the patient for that date of service. However, the carrier maintains the discretion for payment of these services, and reimbursement will be delayed.