Wiki Hospital Discharge Day Management Service

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This applies to Medicare only. My question is who can bill discharges services?

Codes 99238-99239, in the description of the 2011 CPT book under Hospital Discharge Services it states: "To report concurrent care services provided by a physician(s) other than the attending physician, use subsequent hospital care codes (99231-99233) on the day of discharge."

In the Medicare Claims Processing Manual Chapter 12 it states:
B. Hospital Discharge Day Management Service

Hospital Discharge Day Management Services, CPT code 99238 or 99239 is a face-to-
face evaluation and management (E/M) service between the attending physician and the
patient. 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. Only one hospital discharge day
management service is payable per patient per hospital stay.

Only the attending physician of record reports the discharge day management service.
Physicians or qualified nonphysician practitioners, other than the attending physician,
who have been managing concurrent health care problems not primarily managed by the
attending physician, and who are not acting on behalf of the attending physician, shall use
Subsequent Hospital Care (CPT code range 99231 – 99233) for a final visit.

Medicare pays for the paperwork of patient discharge day management through the pre-
and post- service work of an E/M service.

This tells me that only the attending MD can bill codes 99238 or 99239 but one of our providers is disputing this based on the last sentence in the Claims Processing Manual that says "and who are not acting on behalf of the attending physician, shall use Subsequesnt Hospital Care for a final visit" They are saying that because the hospitalist is seeing the patient then they are acting on behalf of the attending physician.

To me it seems pretty clear that these codes can only be billed by the attending physician, but I would love to hear others opinions on this one! Gotta love Medicare!
 
"Concurrent"

I believe the key word in the CPT description is "concurrent." If there is a physician who is performing the discharge day services on behalf of the attending physician, I do not believe these services are "concurrent", as these are the services that would be done by the attending MD if he or she were present. Also, depending on the hospital's policies or hospitalist staffing levels. there could be more than one hospitalist who saw the patient as the "attending" physician. "Concurrent" services, IMO, would be those performed by specialists or other physicians who followed the patient during the hospitalization, but were not ultimately responsible for determining if the patient was ready for discharge.

Therefore, in your situation, I believe the physician is correct and if he or she is performing the discharge service on behalf of the attending, then that physician can bill 99238 or 99239 as appropriate.
 
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