Cardiology Coding Alert

Look to outpatient E/M codes if you don't meet this requirement.

In effect for about a year now, CPT®'s subsequent observation care codes have been something of a mystery since they were released, but CMS finally ended that by issuing clarifications about how to report these codes.

Pinpoint Services Included in 99224-99226

The codes in focus are 99224-99226 (Subsequent observation care, per day, for the evaluation and management of a patient ...).

CMS notes that subsequent observation care pay includes "all the care rendered by the treating physician on the day(s) other than the initial or discharge date," according to MLN Matters article MM7405, with an implementation date of Nov. 28, 2011.

In addition to specifically referring to the "treating physician" in the above passage, the agency goes on to qualify that any other physicians evaluating or consulting on the observation care patient "must bill the appropriate outpatient service codes," and not the subsequent observation care codes. This eliminates prior confusion that existed about exactly which physician could report subsequent observation care.

MAC advice: WPS Medicare, a Part B payer in multiple states, put its advice in writing back in January 2011, noting that "only the physician admitting the patient to observation care status may bill these codes," including the admission (99218-99220), subsequent observation (99224-99226), and discharge from observation (99217) procedure codes. Anyone else seeing the patient while in observation care would bill using an office or other outpatient procedure code (99201-99215), as appropriate.

Tip: It isn't the norm, but "there are situations where a patient is admitted to observation and remains in that status for three or more days," says Jill Young, CPC, CEDC, CIMC, owner of Young Medical Consulting LLC in East Lansing, Mich. And, indeed, CMS expects use of the subsequent observation care codes to be "rare," noting, "In the rare circumstance when a patient receives observation services for more than two calendar days, the physician will bill observation services furnished on day(s) other than the initial or discharge date using subsequent observation care codes."

To read the complete MLN Matters article, visit www.cms.gov/MLNMattersArticles/Downloads/MM7405.pdf.