"If the patient was in the hospital for under 24 hours, it would be considered outpatient. If the patient was in the hospital 24 hours or more, that would be considered inpatient."
The statement you quoted above is not exactly correct. A patient can be considered in observation (outpatient) status longer than 24 hours without being admitted to inpatient. In the case of the example above it is highly unlikely to never that this type case/patient would be inpatient. There could be exceptions of course. Medicare and CPT and/or commercials payers may have different instruction and rules about this.
Example:
www.novitas-solutions.com
www.novitas-solutions.com
Learn about the changes to the hospital inpatient and hospital observation E/M codes.
www.facs.org
www.acep.org
What you have quoted above looks like an attempt at closed reduction note and stating they will take the patient for what looks like ORIF the next day. Just because they use the words, "plan to admit the patient" that doesn't mean admit to inpatient. You would have to look at the orders. It's most likely admit to observation pending surgery. As for an E/M there is no documentation of that in the information you have above. It's possible you may only be able to bill for the closed reduction depending on the documentation.
In the first post you said your doc closed reduced and then D/C the same day, but then the following note says, "admit the patient, npo after midnight for OR in the morning". But then the attached note says, "planning for a closed reduction versus pinning this morning". Which was it? You would need to work off the final, authenticated documentation. It's difficult to see what actually happened here. Did he see the patient in the ED only and not reduce, admit to observation, take to OR in the morning and do a closed reduction only? If so, you would see an E/M-57, and the surgery separately. Wouldn't be a consult since he took over care.
Another example, let's say Dr. ED sees the patient for the ED visit, tries to reduce, can't reduce. Calls in Dr. Ortho. Dr. Ortho comes in and does the reduction and says, yup but we have to take you for ORIF tomorrow, and you'll be under observation pending surgery. You would expect to see the ED E/M by Dr. ED (e.g. 99283), **possible** closed reduction (e.g. 25605 maybe, depends, maybe 52 mod or maybe not at all?) by Dr. ED. Dr. Ortho might only bill (25605) depending on the documentation, there would have to be enough to support a separate E/M. It is *possible* you might also bill (99222-57) depending on the documentation and/or date of service(s). It's probably not going to be a consult code because if Dr. Ortho is taking over care it's not a consult. The following day if ORIF you would probably see a code such as 25607-58, etc. depending on growth plates or not/the documentation.
Of course, you would have to consider modifiers depending on what codes were billed. It will most likely involve use of 25, 57, 58.
Also, read the CPT guidelines at the beginning of each section of the E/M codes, it explains when or when not to use the particular codes. And, consider payer which is most likely commercial or MCD in this case.