Does anyone know if these can only be used by the physician who admits the patient to observation? CPT states For observation encounters by other physicians, see Office or Other Outpatient Consultation codes (99241-99245) or subsequent observation care codes (99224-99226) as appropriate. Our JMAC -- Highmark Medicare Services had a teleconference last week on Practitioner Observation Services, and they indicated that these subsequent observation care codes should only be used by the Attending practitioner, all other practitioners are to use office/outpatient codes 99201-99205 or 99211-99215. I'm trying to determine if I am misinterpreting CPT guidelines.