Wiki Outpatient observation coding assistance

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Houston, TX
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Good morning all,

If my physician is called in to consult a patient that is in observation, which codes would be appropriate to bill? Would I use the observation codes 99218-99226 or outpatient 99202-99205, 99212-99215? I look forward to hearing your opinions and thank you in advance!
 
The observation services codes can only be billed by the provider (group) that ordered the observation services. The consulting provider would bill the outpatient codes 99201-99205 and 99211-99215 depending on whether the patient is new to the provider or not. Per CMS:

In the CY 2011 PFS final rule with comment period (CMS-1503-FC), CMS recognized the newly created CPT subsequent observation care codes (99224-99226). For the new subsequent observation care codes, the current policy for initial observation care also applies to subsequent observation care. Payment for a subsequent observation care code is for all the care rendered by the ordering physician on the day(s) other than the initial or discharge date. All other physicians who furnish consultations or additional evaluations or services while the patient is receiving hospital outpatient observation services must bill the appropriate outpatient service codes. In the rare circumstance when a patient receives observation services for more than 2 calendar dates, the physician shall bill observation services furnished on day(s) other than the initial or discharge date using subsequent observation care codes.
https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads/R2282CP.pdf
 
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