I, personally, would say "established" but only because the wording in the CPT book states:
"...a patient who has received any professional services by that physician in the last 3 years."
So I would say that a hospital admit would count as a professional service.
On another note, if you look at the decision tree on page 5 of the 2010 CPT book, it also may depend on whether the patient is being seen for the same specialty or subspecialty, but I am assuming, for this case, that the patient is probably following up after the initial hospital visit, but that is only an assumtion.
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