Writing orders is considered part of subsequent hospital care. Since the patient was seen that same day (by another provider in the group), all material services furnished for that DOS are bundled into one E/M code. Remember that in the hospital environment, time spent in coordination of care (floor/unit time) is considered part of the E/M; in other words, face-to-face encounters with the patient only represent part of time and work spent in managing patients in acute care.
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