Wiki Can ED charge initial observation in this case?

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I'm not very well versed in ED e/m policies, but I've been doing e/m coding for a long time for our inpatient groups, and I came across this scenario. Can someone with some more expertise help me understand who can code what?

Patient was seen in the cardiologist outpatient office for a routine echocardiogram. The echo revealed a mass on the patient's aortic valve. Patient was contacted by the doctor reading the echo and told to present to the emergency room. The emergency room saw the patient and made a note to place the patient in ED observation at 16:15pm, then called the on-call cardiologist. The on-call cardiologist placed the order for admission to observation status at 16:55pm and is listed as the admitting and supervising physician. The patient stayed in the hospital under observation status for another 2 days before being sent home by the cardiology team. Here is what I'm told should be charged for the initial date of service:

ED Physician: 99220
On-call cardiologist: 99226

I don't think this sounds right. In my opinion, since the ED physician only placed a note stating ED observation, and the on-call cardiologist placed the order to admit to observation AND is listed as the admitting and supervising physician, then the only e/m charge that day should be by the on-call cardiologist as 99220 since the ED charge would be bundled into the initial observation charge.

Can someone please help me figure this out? I've been going back and forth with my other coding counterparts here as to what is correct. Is there any documentation somewhere substantiating the correct way to code this? Thanks!
 
The cardiologist wrote the order for admission to observation. Therefore the admit goes to the cardiologist, the ED provider charges for ED services. Unless the ED provider actually wrote the order to admit to obs.
 
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