Best answers
I'm a chart auditor for a large urology group and there is some dispute on our providers providing a consult in the ER. Patient is Medicare and we are NOT admitting the patient to our service.

I was told that we should be using 99201-99205 or 99212-99215 as the patient is "out patient" and we were asked to come to the ER to provide a consult. And that Place of Service would still be 23 for the ER. I'm told we are starting to get denials for these.

Should we instead be using the ER codes 99281-99285? Or the outpatient codes with POS 22?

I'm getting a great deal of conflicting information on this situation.

And as an aside- does CMS provide a guide and or list of what POS are appropriate with the E&M codes?

Laurie Joslyn, CPC, CMRS
Last edited:


True Blue
Best answers
If your physician is seeing the patient in the ER and the patient has not been admitted to inpatient or observation status, you should be billing the ER visit codes 99281-99285. Here is the information that was published by Medicare when they discontinued accepting consultation codes - I find this a very helpful guide for E&M coding in the various hospital scenarios:


Your situation is described on page 5: "If the ED physician requests that another physician evaluate a given patient, the other physician should bill an emergency department visit code. If the patient is admitted to the hospital by the second physician performing the evaluation, he or she should bill an initial hospital care code and not an emergency department visit code."

I'm not aware of a specific CMS publication that lists which POS codes can be used with which E&M codes.