Observation Services

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Per Medicare guidelines, only the ordering physician is allowed to bill observation codes. All other physicians who furnish consults or additional evaluations/services must bill the appropriate outpatient service codes. In our particular case, another physician order observation status. Our physician performed the discharge and insists on using a discharge code (99217 Observation Care DC / 99238 Hospital DC). Unable to code 99238, patient was not admitted as inpatient. And I did not think he could use an observation code (99217) since he was not the ordering physician. I am looking for clarification as I am unable to find guidelines pertaining directly to the discharge of a patient from OBS status by the non-ordering physician. Am I correct in thinking he is to choose a level of service 99212 - 99215?

Thank you in advance for any help!