Compliance Officers' Forum

Hello,

Does anyone have a procedure or resource you'd be willing to share on how your organization handles physician billing for consultants who see patients under observation, ED observation, and 'extended recovery' or other outpatient non-observation statuses? Our compliance team is putting together a guide on CPT coding and correct place of service code for various scenarios and would like to compare notes with other physician compliance offices. 

Main points we're trying to clarify - 

For insurances that recognize consultation codes, would a consultant who sees a patient admitted to "ED observation" bill from range 99252-99255? Would the POS code be 22 since an observation order was written, or remain as POS 23 because the patient was a registered ED patient?

If the insurance does not recognize the consultation CPT codes (such as Medicare), would a consultant who sees a patient admitted to "ED observation" bill from range 99282-99285 with a POS 23, or with an office/outpatient 99202-99215 code and POS 22? 

Appreciate anyone willing to share notes on how you handle these scenarios.

Thanks,

------------------------------
Lindsay Koschoreck
Associate Director, Documentation Compliance and Internal Audit
------------------------------

Once the patient's status is changed to observation the codes and the POS should reflect that status, regardless of where in the hospital the patient is located. While a patient is in observation status the codes used for the consult would either be the inpatient/observation consult code set or the inpatient/observation care code set, depending on what the payor allows.

------------------------------
Randi Jelinek
Compliance Director
University of Iowa Health Care
------------------------------

Original Message:
Sent: 11-10-2025 02:00:55 PM
From: Lindsay Koschoreck
Subject: consultants in ED observation and outpatient observation

Hello,

Does anyone have a procedure or resource you'd be willing to share on how your organization handles physician billing for consultants who see patients under observation, ED observation, and 'extended recovery' or other outpatient non-observation statuses? Our compliance team is putting together a guide on CPT coding and correct place of service code for various scenarios and would like to compare notes with other physician compliance offices. 

Main points we're trying to clarify - 

For insurances that recognize consultation codes, would a consultant who sees a patient admitted to "ED observation" bill from range 99252-99255? Would the POS code be 22 since an observation order was written, or remain as POS 23 because the patient was a registered ED patient?

If the insurance does not recognize the consultation CPT codes (such as Medicare), would a consultant who sees a patient admitted to "ED observation" bill from range 99282-99285 with a POS 23, or with an office/outpatient 99202-99215 code and POS 22? 

Appreciate anyone willing to share notes on how you handle these scenarios.

Thanks,

------------------------------
Lindsay Koschoreck
Associate Director, Documentation Compliance and Internal Audit
------------------------------