Wiki E/M Observation consults

nnordhaus

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Canton, MI
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We are a Nephrology group and have been using the E/M 99212-99214 office/other outpatient when consult is ordered for a patient in observation status. One of our patients appealed because they received a bill for a copay and feel we used the wrong CPT because the patient was located in the hospital. The patient received a letter back from Blue Cross stating that we should have used a CPT from code set 99221-99233. Was there a changed we missed? Does anyone have any resource that would corroborate? I have not found anything through my searches.
 
99221-99223 are for initial hospital inpatient or observation care and 99231-99223 for subsequent inpatient hospital or observation stays.
 
Unless the BCBS policy differs from CMS, you billed correctly as the non-admitting/treating physician for a patient in observation status. 99221-99233 are billed only by the admitting/treating physician. Below is from Novitas:
For dates of service on and after January 1, 2023, observation services are billed by the admitting physician using:
- Initial hospital inpatient or observation care: 99221-99223
- Subsequent hospital inpatient or observation care: 99231-99233
- Hospital Inpatient or Observation Care Services (Including Admission and Discharge Services): 99234-99239
- Hospital Inpatient or Observation Discharge Services: 99238-99239
All other physicians billing
Observation care codes are billed only by the treating physician. All other practitioners who provide consultations or additional evaluations or services while the patient is receiving hospital observation services bill office and other outpatient visits, codes 99202-99205 or 99211-99215. The new vs. established patient rules apply.
 
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