October 24, 2007
Observation Care Codes (CPT Codes 99234 through 99236)
This article is a reprint from the Medicare Bulletin March/April 2001. Recent inquiry into time and date of service requirements for these services prompted republication of this article to remind providers that for Medicare purposes there are guidelines that are not outlined in the AMA – CPT Manual.
This explains the use of CPT codes 99234 through 99236:
- For a physician to appropriately report CPT codes 99234 through 99236, the patient must be an inpatient or an observation care patient for a minimum of eight (8) hours on the same calendar date.
- When the patient is admitted to observation status for less than eight (8) hours on the same date, the physician must use CPT codes 99218 through 99220 and no discharge code must be reported.
- When patients are admitted for observation care and then discharged on a different calendar date, the physician must use CPT codes 99218 through 99220 and CPT observation discharge code 99217.
- When patients are admitted to inpatient hospital care from observation care and then discharged on a different calendar date, the physician must use CPT codes 99221 through 99223 and CPT hospital discharge day management codes 99238 or 99239.
- For an inpatient admission from observation care with discharge less than 8 hours later on the same calendar date, CPT codes 99221 through 99223 must be used for the admission service, and the hospital discharge day management service must not be billed.
The physician must satisfy the documentation requirements for both admission to and discharge from inpatient or observation care to bill CPT codes 99234, 99235, or 99236. The length of time for observation care or treatment status must also be documented.
References: Physician Fee Schedule Final Rule, Vol.65, No. 212, published November 1, 2000; pages 65408 – 65409.

