Hello! Please help if you can! We are emergency medicine and OBS physician coders and our hospital has a separate observation unit, with it's own tax ID. If a patient was placed in OBS, we bill 99818-99220, 99234-99236, 99217 (whatever applies). Here is the problem.. If a patient was placed in OBS, and then on the second day of their OBS visit they are admitted to the hospital, then we will only bill for their first day and use the medical decision making from their entire OBS visit to determine a level.. which in most cases ends up being 99220. Now compliance is stating that if the patient is admitted on the second day of their OBS visit, they want us to use 99218-99220 for ther first day and then 99231-99233 for the second day. Here are my issues with this:

1. 99231-99233 are subsequent INPATIENT codes, and I do not see how these can be coded unless an INITIAL INPATIENT code is used first.

2. Our physcians are under the OBS tax ID, they are outpatient physicians, they are not credentialed for inpatient, therefore we do not understand how we can bill inpatient codes

3. Shouldn't this be billed by the admitting physician? The physcian that comes down, does their own assesment and exam to determine if they want to admit the patient?

We only use outpatient codes in our department. If a patient is admitted to the hospital from the ED, we do not use any type of inpatient codes, we still use only 99281-99285. So why would we use inpatient codes for our outpatient OBS department? Please help clarify in any way you can! Thanks in advance!!!