Ambulatory Coding & Payment Report
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Reader Question: Observation



Question: When a patient is admitted for observation directly from the physician's office, should we assign and bill an E/M code? 

Michigan Subscriber
 
Answer: The following answer is an excerpt from the Centers for Medicare and Medicaid Services FAQs on claims at its outpatient prospective payment system (OPPS): Because observation is a packaged service, it will not be reimbursed if it is the only OPPS service on a claim. However, the admission of a patient to observation generally involves a low-level E/M visit, which the hospital bills, and whatever office visit the physician who arranged for the admission billed. Therefore, when a patient arrives for observation arranged by a physician in the community (a so-called  "direct admit to observation") and is not seen or assessed by a hospital-based physician, the hospital may bill a low-level visit code. This level visit code will capture services such as the baseline nursing assessment, creating a medical record and recording and initiating telephone orders. 

 Billing tips:
 
  • You can code the visit only once during the observation period.
     
  • Show the observation charges in revenue code 762, and the number of hours the patient was in observation status in the units field.                  
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  • Payment for those services is packaged into the APC for the visit. Other services performed in connection with observation, such as lab and radiology, should be billed as well. 

  • Note: The medical necessity of observation is questionable when a physician does not need to attend.


    - Published on 2001-07-01
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