I keep seeing this issue come up. According to Medicare 99499 is NOT to be used to fill the gap between two level of E&M service within a category or subcategory.
Medicare B news Issue 237 May 29 2007 states
" CPT code 99499 NEVER to be used to interpolate between two levels of E/M service within a category or subcategory. Rather the next lower code for which ALL criteria are met is the appropriate choice"
When talking about "admiting a patient to inpatient status from observation subsequent to the date of admission to observation, the physician must bill an intial hospital visit for the services provided on that date"
#2 If criteria for even a 99221 "inpatient admission" are not met, but a service was necessary, and all of the required componenets performed and appropriately documented meet criteria for a "subsequent Visit" (99231-99233) then that level of service is appropriate for billing and payment (even though the service is chronilogically an "admission")
Consults are also billed as the level of service the meet.
This is in the Medicare Claims Processing Manual, IOM 100-04 Chapter 12-Physician/Practioner Billing, 30.6.1.
Hope this helps clear up some confusion.
Wendy