Medicare Blog

how to bill a consult in observation with medicare

by Orin Streich III Published 2 years ago Updated 1 year ago
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When a specialist is called in to see a patient in observation, that service should be billed using the new patient E/M codes (99201-99205), as long as that patient has not been seen by anyone in that specialist’s group and of the same specialty within the last three years.

That's simple: If a patient is placed in observation on one calendar date and discharged on another, report an initial observation care code (99218–99220) for the first day, then the observation discharge code (99217) on the calendar date of the discharge.

Full Answer

Can a consultatant bill for observation care?

For Medicare patients only 99201-99215 can be billed by a Consultatant but for other plans that do not allow consultation codes, subsequent observation care codes 99224-99226 are appropriate.

Can a consulting physician Bill a Medicare patient in OBS?

Only the admitting physician can use initial and subsequent observation codes for Medicare patients in OBS. Some commercial payers still recognize outpatient consults, and allow a consulting physician to bill subsequent observation codes. But Medicare does not.

Can a doctor Bill a 99203 for an observation patient?

Doctors have the same documentation requirements for a 99203 billed for an observation patient as they would in an office or hospital outpatient clinic. And remember: Only the physician attending in observation can bill the codes in the observation section of the CPT manual.

Who can use initial and subsequent observation codes for Medicare patients?

Only the admitting physician can use initial and subsequent observation codes for Medicare patients in OBS. Some commercial payers still recognize outpatient consults, and allow a consulting physician to bill subsequent observation codes.

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How do I bill observation hours to Medicare?

Another wrinkle: Medicare has an eight-hour minimum for physicians reporting observation same-day-discharge codes (99234-99236). If a patient is in observation for less than eight hours on one calendar day, you would bill initial observation care codes (99218–99220). But you can't bill a discharge for that patient.

How do you bill observation consultation?

If you ask another physician to see your patient during his or her observation stay, that physician should use office or outpatient visit codes 99201-99215 or outpatient consult codes 99241-99245.

Does Medicare accept observation codes?

Same-day observation admit/discharge codes 99234-99236 for Medicare patients must include a minimum stay of at least 8 hours. For duration of less than 8 hours on the same date, the Initial observation code series 99218-99220 are used for Medicare patients.

What is the reimbursement that Medicare uses for observation services?

Observation services are reimbursed under the Outpatient Prospective Payment System using the CMS-1500 as an alternative to inpatient admission. To report more than six procedures or services for the same date of service, it is necessary to include a letter of explanation.

What is the POS code for observation?

POS 22If a patient was in observation, then use POS 22. But if the patient was actually admitted and discharged on the same day, then go with POS 21.

Does Medicare pay for consultations?

Pursuant to 42 CFR § 411.351 and section 15506 of the Medicare Carriers Manual, Medicare allows reimbursement for consultations if (1) a physician requests the consultation, (2) the request and need for the consultation are documented in the patient's medical record, and (3) the consultant furnishes a written report to ...

What type of bill is used for an observation claim?

Therefore, hospitals should bill HCPCS code G0378 when observation services are provided to any patient in “observation status,” regardless of the patient's condition.

What criteria must be met to bill a Medicare patient as an inpatient observation patient?

For a physician to bill observation care codes, there must be a medical observation record for the patient which contains dated and timed physician's orders regarding the observation services the patient is to receive, nursing notes, and progress notes prepared by the physician while the patient received observation ...

How are observation hours calculated?

Observation time begins at the clock time documented in the patient's medical record, which coincides with the time that observation care is initiated in accordance with a physician's order. Observation time ends when all medically necessary services related to observation care are completed.

Does Medicare cover observation?

Medicare considers observation care an outpatient service. Outpatient services are covered under Medicare Part B, which means that patients on observation status have fewer Medicare benefits and will pay more out of pocket.

What is observation billing?

Billing for observation services can be confusing, particularly when an observation stay lasts more than one day or when a patient's status changes from observation to inpatient. Observation services include initiating observation status, supervising the care plan and reassessing the patient periodically.

How are observation services currently reimbursed under opps?

Describe how observation services are currently reimbursed under OPPS. Observation services are reimbursed via two composite APCs.

When a Medicare patient is admitted, and another physician provides a consultation for that patient, the situation may arise in?

When a Medicare patient is admitted, and another physician provides a consultation for that patient, the situation may arise in which both the admitting physician and consulting physician would report an initial inpatient service (e.g., 99221-99223). To differentiate between the two physicians’ services, and to prevent a claims denial for duplication of services, the admitting physician should append modifier AI Principal physician of record to the initial inpatient service code.

What is the code for a hospital consultation?

Inpatient consultations should be reported using the Initial Hospital Care code (99221-99223) for the initial evaluation, and a Subsequent Hospital Care code (99231-99233) for subsequent visits. In some cases, the service the physician provides may not meet the documentation requirements for the lowest level initial hospital visit (99221).

Why would an endocrinologist not append modifier AI?

But, the endocrinologist would not append modifier AI because he is not the admitting physician overseeing the patient’s overall care. Per CMS guidelines, “In all cases, physicians will bill the available code that most appropriately describes the level of the services provided.”.

What is an example of an ED visit?

For example: A patient presents to the emergency department with chest pain. The ED physician evaluates the patient and codes an ED visit (99281-99285). He also requests a consult from a cardiologist. The cardiologist evaluates the patient and decides to admit him. The admitting cardiologist would report an initial hospital visit (99221-99223) with modifier AI appended.

Does Medicare accept 99241?

Consultation Coding for Medicare. Medicare does not accept claims for either outpatient (99241-99245) or inpatient (99251-99255) consultations, and instead requires that services be billed with the most appropriate (non-consultation) E/M code.

Does CMS expect CPT code to be accurate?

While CMS expects that the CPT code reported accurately reflects the service provided, CMS has instructed Medicare contractors to not find fault with providers who report a subsequent hospital care CPT code in cases where the medical record appropriately demonstrates that the work and medical necessity requirements are met for reporting a subsequent hospital care code (under the level selected), even though the reported code is for the provider’s first E/M service to the inpatient during the hospital stay.

What is the code for outpatient consultation?

For private carriers that may not have adopted Medicare’s prohibition on consult codes, use outpatient consultation codes (99241-99245) .

When to use 99234-99236?

You recommended billing the service with a 99234-99236 (observation, admit and discharge on the same date) and using only the date of day 2 as the service date.

How many hours apart should you see a patient on day 2?

The bulletin states: “NAS recommends the use of CPT 99234-99236 (observation or inpatient care services including admission and discharge services) if the patient is seen on at least two separate occasions on day 2 and these separate occasions are at least 8 hours apart.”

What is the hospital code for Jan 4?

A: Bill your Jan. 4 services with a hospital discharge service code (99238-99239) . Because the patient was then admitted to observation status, code the Jan. 5 visit service with an initial observation care code (99218-99220) and then use the observation discharge code (99217) on Jan. 6. The hospital’s records should support both the inpatient discharge and the observation services.

Can you use outpatient codes for observation?

A: Because observation patients have outpatient status, you would use outpatient consult codes. Here’s where it gets tricky: Under new Medicare guidelines, you can no longer submit outpatient consult codes (or inpatient ones, for that matter). Instead, use the initial office visit codes (99201-99205).

What is the CPT code for observation discharge?

Observation discharge service is reported using CPT code 99217 if the discharge is on other than the initial date of observation care. Procedure code 99217 includes all services provided to a patient on the day of discharge from outpatient hospital observation status.

Why do contractors specify bill types?

Contractors may specify Bill Types to help providers identify those Bill Types typically used to report this service . Absence of a Bill Type does not guarantee that the article does not apply to that Bill Type. Complete absence of all Bill Types indicates that coverage is not influenced by Bill Type and the article should be assumed to apply equally to all claims.

What is the limitation on certain services furnished to hospital outpatients?

This specifies that services provided to an inpatient or outpatient of a hospital are covered only when that primary hospital bills Medicare for the services.

What is the rule for an inpatient admission?

The general rule is that the physician should order an inpatient admission for patients who are expected to need hospital care to extend through two midnights or longer and treat other patients on an outpatient basis.

What is CMS in healthcare?

The Centers for Medicare & Medicaid Services (CMS), the federal agency responsible for administration of the Medicare, Medicaid and the State Children's Health Insurance Programs, contracts with certain organizations to assist in the administration of the Medicare program. Medicare contractors are required to develop and disseminate Articles. CMS believes that the Internet is an effective method to share Articles that Medicare contractors develop. While every effort has been made to provide accurate and complete information, CMS does not guarantee that there are no errors in the information displayed on this web site. THE UNITED STATES GOVERNMENT AND ITS EMPLOYEES ARE NOT LIABLE FOR ANY ERRORS, OMISSIONS, OR OTHER INACCURACIES IN THE INFORMATION, PRODUCT, OR PROCESSES DISCLOSED HEREIN. Neither the United States Government nor its employees represent that use of such information, product, or processes will not infringe on privately owned rights. In no event shall CMS be liable for direct, indirect, special, incidental, or consequential damages arising out of the use of such information, product, or process.

What is the CPT code for evaluation services?

Evaluation services (consults) requested of other physicians and qualified NPPs while the patient is in observation care are reported as office or other outpatient visit CPT codes 99202-99205 or 99211-99215.

Can you use CPT in Medicare?

You, your employees and agents are authorized to use CPT only as contained in the following authorized materials of CMS internally within your organization within the United States for the sole use by yourself, employees and agents. Use is limited to use in Medicare, Medicaid or other programs administered by the Centers for Medicare and Medicaid Services (CMS). You agree to take all necessary steps to insure that your employees and agents abide by the terms of this agreement.

What is the code for outpatient care in 2021?

In 2021, the documentation requirements for codes 99202—99215 changed. These office and other outpatient codes are used in the office, or in a hospital outpatient department. They are also used by the consulting physician for Medicare patients receiving observation services, which is an outpatient service. The changed documentation rules go ...

Can a 99204 be billed as a 99221?

However, if the patient’s status changes to inpatient status, the physician would be limited to a level one initial hospital service, 99221 because of the level of history and exam.

Does Medicare recognize outpatient consults?

Some commercial payers still recognize outpatient consults, and allow a consulting physician to bill subsequent observation codes. But Medicare does not.

Can a physician use a Medicare observation code?

For Medicare patients in observation, the consulting physician uses new and established patient visit codes. Only the admitting physician can use initial and subsequent observation codes for Medicare patients in OBS.

When is observation not considered medically necessary?

Observation services are not considered medically necessary when the patient’s current medical condition does not warrant observation, or when there is not an expectation of significant deterioration in the patient’s medical condition in the near future.

What is outpatient observation?

Outpatient observation services are covered only when provided by order of a physician or another individual authorized by state licensure and hospital staff bylaws to admit patients to the hospital or to order outpatient tests. Do not order observation services for a future elective surgery or outpatient surgery cases.

What is an inpatient admission?

An order simply documented as “admit” will be treated as an inpatient admission. A clearly worded order such as “inpatient admission” or “place patient in outpatient observation” will ensure appropriate patient care and prevent hospital billing errors.

What is an observation status?

Observation status. Outpatient; released when the physician determines observation is no longer medically necessary. Physician’s order is required. Lack of documentation can lead to claim errors and payment retractions. An order simply documented as “admit” will be treated as an inpatient admission.

How long after observation can you get a moon?

Hospitals and CAHs may deliver the MOON to a patient receiving observation services as an outpatient before the patient has received more than 24 hours of observation services but no later than 36 hours after observation services begin.

How many hours of observation is considered non-covered?

Note: For non-OPPS providers, if the total hours of observation exceed 72, a second line of observation should be billed and the additional hours, which are considered medically unlikely, should be billed as non-covered.

How long does it take to get a MOON notice from Medicare?

All patients receiving services in hospitals and clinical access hospitals (CAHs) must receive a Medicare outpatient observation notice (MOON) no later than 36 hours after observation services as an outpatient begin.

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