Gastroenterology Coding Alert

Question: For all patients under observation admitted in our facility we have been using outpatient consult codes with POS 22 (outpatient). Recently, we were told that if the patient continues to remain under observation for another day, we should use a hospital visit code with POS 21 (inpatient). This is contradictory to how we have been reporting it as we continue to use POS 22. Please tell us what is appropriate?

Texas Subscriber

Answer: For patients under observation, the appropriate outpatient consult code (99241-99244) with POS 22 (outpatient) is the right way to report for the first day. The reporting for observation on the subsequent day is in the same manner depending on the patient's condition as reported in the documentation provided by the doctor.

If other physicians, other than the admitting physician, are checking the patient while under observation, you have to bill their services using appropriate outpatient consultation or service codes as is relevant. Also, if the doctor and the physician who puts the patient under observation are different, then the doctor's services should also be reported using the appropriate outpatient codes.

If the period of observation extends beyond two days, the admitting physician should bill the visit on the discharge date with relevant outpatient visit code. You have to use appropriate outpatient consult and service codes for visits by other physicians for multiple days of observation.

Warning: It is wrong to use hospital inpatient codes (99231-992333) or the POS 21 (inpatient) for patients that have been admitted for the purpose of observation, irrespective of the number of days that they are in the hospital for that reason.