Pulmonology Coding Alert

Question: Who can bill the 99238 discharge on a Medicare patient? Does it have to be the admitting physician only?

Connecticut Subscriber

Answer: The attending physician of record -- often times the admitting physician -- or a physician from the same group and specialty is the only one who can report 99238 (Hospital discharge day management; 30 minutes or less), according to CMS.

However, as a consulting pulmonologist you still have some recourse. CMS offers some guidance when another physician or qualified non-physician practitioner (NPP), such as a physician assistant or nurse practitioner, who has been managing other aspects of the patient's health not covered by the primary physician, discharges the patient.

For those pulmonologists "who are not acting on behalf of the attending physician," you should bill their services with a subsequent hospital care code (99231-99233, Subsequent hospital care, per day, for the evaluation and management of a patient ...) for their final visit.