Wondering exactly what's required to justify billing observation and assessment code G0163? Well, direct physician contact shouldn't be among the requirements. So said CMS officials in the April 11 Open Door Forum for home care providers. HHAs are being told that the clinician must have directly contacted the physician for the visit in which the code is used, a caller told CMS in the forum. That's not the case, said a CMS rep. But the record must show that there was a reasonable potential for a complication or acute episode, the rep added. (For more tips on billing O&A, see Eli's HCW, Vol. XXI, No. 17, p. 130).