ED Coding and Reimbursement Alert

Reader Question:

E/M Bundled With Observation Status

Question: In the past we have collected payment for both the echocardiograph (EKG) observation code and ED E/M level of service. Our understanding has been that the physician performed (and documented) additional work to admit the patient to EKG observation status, and therefore the ED visit and the observation status were separate. Are we correct?

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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