DecisionHealth, DecisionHealth - 2011 Issue 9 (September)
Two major CMS clarifications on subsequent observation codes
You can’t add prolonged services on top of the new subsequent observation codes (99224-99226), and you now have explicit rules from CMS on whether the admitting or consulting physician should bill subsequent observation. CMS has clearly taken a position against CPT, which means you may have to code differently for Medicare patients and privately insured patients who get the same services in the same situation.
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