Question Billing Observation Codes for Trauma Group


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HI. I am have been getting conflicting guidelines on Observation Billing and need a final determination. Our Trauma Surgeon admitted a patient for Observation on 07/06/2019 and another member of our Trauma Group subsequently saw and discharged the patient same day. I billed each MD for the correct E&M Observation code, but one of the employees has me doubting myself stating that two MD's within the same practice cannot bill with two separate codes, same day. She is stating that I need to combine the codes and bundle the billing under one MD. This was stated somewhere as a Medicare guideline, but all of the info I have been reading says to report each MD (as per the legal medical documentation) as "Payment policies can vary from payer to payer". I printed some written material stating that the criteria: "Both the admission and discharge notes are written by the billing physician (OR MAY BE BILLED BY 2 PHYSICIAN'S WITHIN THE GROUP PRACTICE).

Would like to get this resolved in writing to present to our Medical Director.




Brainerd, MN
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Hi Camille,
Just an FYI - it is always super helpful when asking for help to state which procedure code(s) you are billing. Especially if you are reaching out to a colleague or coworker for advice and their answer may differ to provide their answer also. I don't have enough information to agree or disagree but will explain.
I do see this scenario working as a coding analyst and hopefully I may be able to help.

Random Example: Let's say a patient comes into facility at 0027 with a medical issue and was seen by department "Trauma Team" Team Member AA and are placed into "observation" status. Shift then changes at 6 AM and then around 2 PM that same day the patient now has overcome their medical issue and is ready to go home and is discharged by another member of "Trauma Team" (on the same DOS) Team Member BB.

I am going to provide an example - 99219 Initial Observation Care provided by Team Member AA along with 99217 Observation Care Discharge provided by Team Member BB being billed for the same DOS. These charges have a bundling issue per Charge Assist ("typically" billed on the CMS).
We cannot bill 99217 with 99219 (there is no modifier allowed).

For our Component 2 procedure code 99217 this is not billable - the guidelines go on to provide additional details "Observation care discharge day management (This code is to be utilized to report all services provided to a patient on discharge from outpatient hospital "observation status" if the discharge is on other than the initial date of "observation status" or "inpatient status" and discharged on the same date, use the codes for Observation or Inpatient Care Services [including Admission and Discharge Services, 99234-99236 as appropriate]." Also review your guidelines in our CPT book. I was provided the AMA CPT Professional 2019 book and am reviewing page 18.

Per our facility's guidelines for this scenario, I will bill the appropriate code from "Observation or Inpatient Care Services (Including Admission and Discharge Services) assigning the appropriate code after reviewing both provider's notes from our "Trauma Team" provider AA and provider BB documentation to support billing our charges. Per policy I will also assign the billing and service provider as the admitting physician.

I fully understand finding information (but please be cautious & leary and concentrate on your reliable sources ~ there is simply a lot of nonsense out there).

Hopefully this clears the "mud" for your coding and also please reach out with any other questions.
Thanks for listening this evening,
Coding Associate (May 2018-present), Anesthesia, Pathology, Laboratory Coder (Fall 2012-May 2018)