Who is the payer? This matters because Medicare (and other government payers) will not accept a counter signature from the teaching physician as adequate documentation of service provided, while most commercial payers allow this (supervision being by any means of modern communications, including available by phone).
Let's assume this is a Medicare patient who is admitted by the resident in the evening on 4-1-11.
Teaching physician has his initial hospital visit with the patient on morning of 4-2-11 and determins patient can be discharged. The TP's documentation (NOT the resident's) can be used to code 99234-99236 for services provided and documented on 4-2-11.
Hope that helps.
F Tessa Bartels, CPC, CEMC
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