ED Coding and Reimbursement Alert
E/M Bundled With Observation Status
Stacey Levitt
Caduceus Inc., Chicago
Answer: No. Generally, the rule for physician billing is one E/M per calendar date. The ED visit (99281-99285) payment is included in the admission to observation (99234-99236, observation care levels 1-3; 99218-99220, initial observation care levels 1-3). Codes 99217-99220 are used if the observation stay occurs over two calendar days. If the observation visit spans only one calendar day, codes 99234-99236 are used.
According to CPT, When observation status is initiated in the course of an encounter in another site of service, all E/M services provided by the supervising physician in conjunction with initiating observation status are considered part of the initial observation care when performed on the same date. It also specifically states, E/M services on the same date provided in sites that are related to initiating observation status should not be reported separately [emphasis added].
If the services are provided on different dates or by unrelated providers, they may be separately billable.
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