Wiki Swing Bed E/M Admit Documentation

Sabrina.

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There is an issue on what documentation is required to code an admit E/M level when a pt is discharged from IP or observation (obs) to swing bed in the same facility.
*Our providers are trying to use the H/P (from IP or obs admit) for the swing bed admit.
Ex) pt admitted to IP on 9/20/2023, discharged to swing bed on 10/1/2023... H/P from the IP admit (9/20) is being given for the swing bed admission which leaves me without the ability to provide an admit E/M because there is nothing in the swing bed chart showing the patient was seen/treated.

Here are the contradicting pieces of information I've located:
- The guidelines state the time & care related to hospital IP or observation "may not be used for code selection" which seems to be clear in not using the prior documentation towards the current, swing bed, E/M leveling.
- There is an MLN that states documentation requirements as:
  • Acute d/c orders, including d/c summary (which is only present in the IP or observation chart)
  • Admission orders to swing bed status (which is always present in the swing bed chart)
Of note: it's acceptable to have an IP or obs discharge E/M level on the same day as a swing bed admit E/M level for the same provider but the accounts are entirely separate &, historically, require an h/p, applicable progress notes & d/c summary.
Again, noting that an E/M level for provider reimbursement cannot be coded without documentation that the patient was seen/care provided on the given date of service.

So, can the providers replace the swing bed admission h/p with the d/c summary & orders? IF on the same dos, can they receive an E/M admit level allowing for provider reimbursement? AND should a notation be added to the d/c summary stating the documentation is being submitted as h/p as part of the swing bed chart? Admittedly this makes sense to me in cases where Dr. A is discharging from IP or observation & admitting to swing bed on the same day.
OR
Does the guideline note that the time & care spent in the previous setting not apply to the swing bed codes mean they are going to have to provide the h/p (which until 2023, they did)?
If there is not supporting documentation provided for the admit E/M, am I able to code the subsequent days? I do not believe this is acceptable & feel would be denied by carriers.
Thanks for the time and help.
 
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