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Answers to questions about timing for discharge and observation codes
by Tamra McLain, CPC, CPC-H, CMC



Published in the August 2005 issue of Today's Hospitalist

The hospitalists in my group are being asked to dictate discharge summaries the day before patients are discharged. The goal is to expedite the care plan, particularly for patients who are going to nursing home facilities.

What should we do when we spend 25 minutes preparing and dictating the discharge summary on Monday in preparation for a Tuesday discharge, but we then see the patient on Tuesday for an additional 10 minutes preparing for discharge? Can we bill for those services using the CPT code for discharge (99239) on Tuesday if we write an addendum saying that the patient is stable and can be discharged as per the summary dictated the day before?

While CPT guidelines for discharge services codes (99238-99239) state that the time you spend on discharge planning doesn’t need to occur in a continuous block, it does clearly state that the time spent on these services should occur on the date of discharge. As a result, it is not appropriate to code for subsequent follow-up services (99231-99233) after you have coded a discharge service.

To simplify matters, I would discourage you from coding for discharge services on two dates (the day before and the day of discharge, for example). I would instead code for all discharge services on the date of discharge, even if you performed some of the dictation on the previous day.

If a patient is admitted for observation one day and then admitted the next day, should I use CPT’s observation codes (99218-99220) or admission codes (99234-99236)? Also, when determining how to code this patient, do I need to factor in the amount of time the patient spent in observation (greater or less than eight hours, for example)?

In the above scenario, the definition/instruction section of the CPT book advises you to use CPT observation codes 99218- 99220 for the first day. On day two, when you admit the patient, use CPT admission codes, 99221-99223.

The amount of time the patient spends in observation does not affect the codes you should use for observation service. While observation services are not specifically based on time, the admit and discharge date must fall on the same calendar day.

If a patient dies in the hospital, what E/M service should the attending physician report to cover the time she spends pronouncing the patient’s death, completing the death summary and talking with the deceased patient’s family members?

When a patient dies, you can use one of CPT’s two hospital discharge codes (99238-99239) as long as you perform any of the criteria included in hospital discharge services. These services include counseling, preparation of discharge records, etc.

Tamra McLain is coding manager for HRA Medical Management Inc. in San Diego. E-mail her your documentation and coding questions or send a fax to 619-280-1347. We’ll try to answer your question in a future issue of Today’s Hospitalist.


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