June 8, 2023
We are wondering if you can help address a discussion in our office related to the coding rule changes for hospital services. CPT instructs to report 99221-99223 (inpatient hospital/observation) and 99231-99223 (subsequent hospital/observation) for both inpatient and observation services. Our hospital does not have a dedicated outpatient observation area; all patients are cared for on the inpatient division. We believe we understand this does not matter for code selection. Here is our question. What is the place of service for the observation patient on the inpatient division now that we are using the same code series?
Yes, you understand the guidelines correctly related to the inpatient/observation codes and physical location- it is about admit status in this situation. You will continue to report the appropriate code from the 99221-99223 and 99231-99233 based on the type of service and the location status of the patient.
If the patient has been admitted as an inpatient, regardless of where there bed is located, you will report the appropriate initial or subsequent hospital inpatient code and the place of service is 21 (Inpatient Hospital).
If the patient is in outpatient observation status (‘admitted’ to observation) you will report the appropriate initial or subsequent observation code and the place of service is 22 (On Campus-Outpatient Hospital (e.g. observation).
POS 19 would not be correct for the patient in observation status as this place of service is Off Campus-Outpatient Hospital.
*This response is based on the best information available as of 06/08/23.