Wiki Discharge Coding - E/M

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For Discharge Day Management Codes 99238 and 99239, the CPT manual description notes that, “These codes are to be utilized to report all services provided to a patient on the date of discharge, if other than the initial date of inpatient or observation status.”

However, as per the Medicare Claims Processing Manual (Pub 100-04 Medicare Claims Processing, Change Request 13064, Transmittal 11842), “The E/M discharge day management visit shall be reported for the date of the actual visit by the physician or qualified nonphysician practitioner even if the patient is discharged from the facility on a different calendar date.”

The question is whether the documentation in the record to support the E/M discharge visit needs to be on the actual date of discharge or can these codes be used if documentation of the discharge day visit is on a different calendar date (i.e. say a day or two prior to the actual discharge date)? Thank you!
 
Follow Medicare: patient seen by physician and prepped for discharge on the evening of 9/25; patient discharged from hospital in early morning hours 9/26. DOS for physician's service is the date they saw the patient, 9/25
 
this is why it pays to do d/c day of or next day. for 9/25 this MD should have used a sub hosp visit & one of the other 2 codes the day of actual discharge. d/c should be billed day it happens. good luck if your documentation doesn't match!!
 
I've seen this scenario a few times. This is my understanding, is this correct?
9/25 - Patient is discharged by provider, discharge summary entered, face-to-face encounter performed/supported. >30 minutes spent, 99239.
9/26 - Patient is officially discharged from the hospital but no provider sees the patient on this date therefore no additional provider e/m supported documentation is entered.

99239 would be changed to subsequent based on time or MDM 99233/99232/99231.

I've given providers feedback on this. Sometimes I come across 2 discharge summaries in this case since the discharge was delayed. The 2nd discharge (matching the discharge date) would be supported, and the first discharge would still be changed to a subsequent. But at least discharge can be billed.
 
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