When Clock Strikes Midnight, Switch Up Observation Coding

Posted on 4 Jan, 2016 |comments_icon 2|By Chris Boucher

Calendar days pace observation service coding.

The rules for observation coding are typically pretty straightforward. Pick 99218-99220 for the first day when the patient is in observation for multiple days; pick 99234-9236 if the observation lasts more than eight hours on a single day.

Monkey wrench: Are you prepared, however, for an observation visit that spans two days but only lasts a few hours? We asked Mary I. Falbo, MBA, CPC, CEO of Millennium Healthcare Consulting in Lansdale, Pa., for her take on these types of observation services. Here’s some expert input on coding observation services that span multiple days, but don’t last very long.

Nuts and bolts: Regardless of what time of day you admit the patient, it’s the date on the calendar that matters, Falbo says. When a patient is admitted for observation care on one calendar date and discharged on a different calendar date, the physician shall report a code from 99218-99220 for the first calendar date and 99217 for the discharge date, explains Falbo.

So if the patient is admitted late one night and discharged a couple of hours later the next morning, you’ll report 99218-99220 for the initial observation service and 99217 for the discharge.

Consider this clinical example:

A patient presents on Thursday night with persistent non-bilious vomiting and mild dehydration. The nurse practitioner (NP) gives the patient a dose of ondansetron, after which he can tolerate sips of liquid. At 11 p.m., the NP places the patient in observation to be sure that he can maintain oral intake. After ensuring the patient’s oral intake ability, the physician discharges the patient at 2:30 a.m. Friday. Notes indicate a level-two observation service.

See also: Are You Sure About that ‘Simple’ FBR? It Could Be an E/M

On the claim, you should report:

  • 99219 (Initial observation care, per day, for the evaluation and management of a patient, which requires these 3 key components: a comprehensive history; a comprehensive examination; and medical decision making of moderate complexity) for the observation service.
  • 99217 (Observation care discharge day management) for the discharge service.


Chris Boucher

Chris Boucher has nearly 10 years of experience writing various newsletters and other products for The Coding Institute. His blog will cover several areas of coding and compliance, including CPT® coding, modifiers, HIPAA compliance and ICD-10 coding.

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