ED Coding and Reimbursement Alert
Complete PFSH Required For Observation Services
Question: Is it always required that a family history be documented before assigning code 99220 or 99236 for comprehensive or high complexity observation services?
New Mexico Subscriber
Answer: You are correct in that the CMS documentation guidelines say that comprehensive observation services, unlike ED E/M, require three of three PFSH elements for the highest level. Also CPT® includes these elements in the definition of a comprehensive History, which is required for observation codes.
Only the lowest level of observation, codes 99218 or 99234 can be billed with a detailed or comprehensive history and physical exam; but what usually droves the observation choice is the level of medical decision making low, moderate or high.
ED Coding and Reimbursement Alert
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