Pulmonology Coding Alert

Question: When a pulmonologist admits a patient from the office and doesn't provide the initial face-to-face service in the hospital until the next day, previous Pulmonology Coding Alert's stress to report the admission on the second day and the office visit on the first day. The articles usually assert that the attending physician has 24 hours to see the patient in the hospital so that the above scenario is acceptable practice. Whose rules allow the pulmonologist to have 24 hours to see the patient?

Florida Subscriber Answer: CMS contains regulations that mandate the physician provide the admission history and physical within 24 hours as part of the "Conditions of Participation" (see www.cms.hhs.gov/SurveyCertificationGenInfo/downloads/SCLetter07-13.pdf).  This federally  mandated hospital requirement then carries over to when the physician may report his initial admission service for professional billing -- within 24 hours, whenever the attending physician provides the initial face-to-face encounter (99221-99223, Initial hospital care, per day, for the evaluation and management of a patient ...).

The rules allow the attending physician 24 hours to interview and examine the patient, review the case with the resident and then write his note, sign and date it. The attending physician has a lot to do before he writes his note, signs and dates it.

When a physician provides the initial hospital care on the day following an office visit, carriers pay both visits, even if fewer than 24 hours has elapsed between the visit and the admission (see www.cms.hhs.gov/manuals/downloads/clm104c12.pdf).