Medicare Compliance & Reimbursement

Question: Our provider admitted a patient for observation, but documentation of initial admission had not been done. We are using office visit codes 99211-99215; however, the patient is seen the following two days in observation. Can we bill subsequent observation codes? Or does the follow-up observation need to be billed with office visits codes as well?

 Answer: When the patient is in observation status and the documentation of admission cannot be confirmed, send a query to the facility asking for documentation of admission.

If you receive inpatient documentation, then report the appropriate inpatient codes (99221-99223). Office visit codes (99211-99215) should not be billed since you are not sure whether the patient was discharged from the observation status.

Initial observation codes (99218-99220) should be billed for initial observation and subsequent observation codes (99224-99226) should be billed for patient seen for two days of continued observation. After two days of observation status, the patient needs to be discharged or admitted as inpatient.

“This is generally a policy and procedure issue,” says Duane C. Abbey, PhD, president of Abbey and Abbey Consultants Inc., in Ames, Iowa. “With the new guidelines on inpatient admissions, unless there is a physician order for admission, the patient will be classified as outpatient.” 

Advice: A good idea is to address this with the physicians so that they are documenting enough for you to report the initial visit.