Since I don't know the specialty of your doc(s), I will elaborate on both ends:
An emergency room physician will always bill within the codes 99281 - 99285 regardless of whether the patient is treated and released or discharged. Remember that if the emergency room doc decides that the patient needs to be admitted, he/she will call in the covering physician or the hospitalist service and it will be that physician who actually takes on the admit.
A non-emergency room physician who sees a patient in the emergency room and treats and releases this patient will also bill from the above codes.
A non-emergency room physician who sees a patient in the emergency room and then admits that patient to either observation status or in-patient status will then take that emergency room evaluation and it will become the admit H&P and no code from 99281 - 99285 will be utilized.
Hope this helps,
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