Evaluation and Management Coding for Observation Status

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Professional services are billed using Evaluation and Management (E/M) codes that are a subset of Common Procedural Terminology (CPT) codes. Effective January 1, 2023, the same E/M code will be used regardless of patient status. In other words, the same E/M code will be used regardless of if the patient is admitted as an inpatient or hospitalized for observation service. This change occurred because the clinical work is similar between observation and inpatient care resulting in the decision to merge observation E/M codes with E/M inpatient codes. The new codes are titled, “Hospital Inpatient or Observation Care Services.

If you were going to report. . . You will now report . . .
99217 Observation Care Discharge Services The following codes depend on the time associated with the visit if the date of discharge is not the same as admission.

99238 Hospital inpatient or observation discharge date management, 30 minutes or less

99239 Hospital inpatient or observation discharge date management, more than 30 minutes

99218, 99219, or 99220 Initial Observation Care The following codes depending on the level of Medical Decision Making (MDM) or time associated with the visit.

99221 Initial hospital inpatient or observation care MDM straightforward or low/40 minutes*

99222 Initial hospital inpatient or observation care MDM moderate/55 minutes*

99223 Initial hospital inpatient or observation care MDM high/75 minutes*

99224, 99225, or 99226 Subsequent Observation Care The following codes depending on the level of MDM or time associated with the visit.

99231 Subsequent hospital inpatient or observation care MDM straightforward or low/25 minutes*

99232 Subsequent hospital inpatient or observation care MDM moderate/35 minutes*

99233 Subsequent hospital inpatient or observation care MDM high/50 minutes*

 

*When billing by time the listed times must be met or exceeded.

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