# Initial Observation Care 99218-99220



## dmraimondi (Jan 12, 2015)

I work for a multispecialty group that often bills the initial observation codes, 99218-99220 with location 22.  We have run into a new issue, the emergency room providers are also using the same codes with location 23.  Has anyone else had this same issue and how did you solve it?


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## cmartin_333 (Jan 18, 2015)

*Initial Hospital Observation*

Per guidelines only the admitting provider can bill for the initial observation.  i agree with POS  22.  It seems to me that the ED providers are billing it with POS 23 because if the admission to Obs is the same day as the ED services then the ED providers will bill POS 23 for the admission.  I don't disagree with that because the services were rendered in the ED and the ED provider admitted the patient after his/her evaluation that same day to further evaluate the patient.

Are the ED providers really admitting the patients to Obs or are they consulting another provider via phone, etc and the other provider gives verbal orders to admit to OBS but does not see the patient until the next day and signs the admission order?  If this is happening then the ED provide-r should bill for the services provided in the ED POS 23 and the admitting provider would bill the initial Obs the day of his/her face to face encounter if the signed written admit order is completed.

This is merely an opinion regarding the ED admits.  I would have to research the POS 23 for initial Obs by an ED physician.

 -C.Mansuy,CPC, CEMC


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## sivagurulingam (Jan 21, 2015)

I hope this is helpful:

Observation services are commonly ordered for patients who present to the emergency department and who then require a significant period of treatment or monitoring in order to make a decision concerning their admission or discharge.  

In only rare and exceptional cases do reasonable and necessary outpatient observation services span more than 48 hours.  In the majority of cases, the decision whether to discharge a patient from the hospital following resolution of the reason for the observation care or to admit the patient as an inpatient can be made in less than 48 hours, usually in less than 24 hours.  

Contractors pay for initial observation care billed by only the physician who ordered hospital outpatient observation services and was responsible for the patient during his/her observation care.  A physician who does not have inpatient admitting privileges but who is authorized to furnish hospital outpatient observation services may bill these codes.  

For a physician to bill observation care codes, there must be a medical observation record for the patient which contains dated and timed physician?s orders regarding the observation services the patient is to receive, nursing notes, and progress notes prepared by the physician while the patient received observation services.  This record must be in addition to any record prepared as a result of an emergency department or outpatient clinic encounter


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