If same Dr admitted pt and did an ORIF on same day as the consult and closed reduction you can only bill for the admission and ORIF.
Per CPT book2009 on pg. 12 under initial hospital care: When the pt is admitted to the hospital as an inpatient in the course of an encounter in another site of service (eg, hospital emergency dept, observation status in a hospital, physicians office, nursing facility) all E & M services are provide by that physician in conjunction with that admission are considered part of the initial hospital care when performed on the same date as the admission.
hope that helps.
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