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Wiki E/M assignment for SDM procedure

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Our nephrologist completes an H&P prior to a same day kidney biopsy procedure. Patient usually stays over night for extended care but still a same day procedure. The nephrologist examines the patient again after the procedure. He was billing these encounters as an observation (which I know is incorrect). Since the patient is known to him - shouldn't he be billing a 99214 or 99215 (depending on complexity). Please advise. Thanks!
 
did you ever get your answer regarding this? I am pondering this same coding issue at this moment. I dont think it should be observation either since the status of stay is never "observation" it outpatient, which to me would only make since to code with a est op cpt.
 
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