Wiki Nursing Facility Discharge vs Subsequent Visit

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Philadelphia, PA
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I have multiple NP's billing visits at Nursing Facilities. Several have started billing 99310 (subsequent visit), for a discharge note instead of 99316. Their note states they are discharging the patient. At times they are writing the discharge note 4 to 5 days in advance of the planned discharge. They do not go back to see the patient on or closer to the date of discharge. I am under the impression they need to bill either a 99315 or 99316 when they are discharging a patient from a Nursing Facility. Can anyone advise me or point me towards any documentation relating to this?
 
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