If the pt was discharged from an observation or an inpt status (some facilities do not have accomodations to designate an area called "observation") of less than 24 hours and has not been fromerly admitted to the hospital, then the 99217 is appropriate. If a physician has admitted the pt then discharges and meets the requirements for 99234-99236 then bill that E&M.
99238 is used if the pt has been formerly admitted and is discharged on a different day (but an admit code needs to be submitted to be able to utilize this code)
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