Several readers have written to FPM questioning the advice given by Kent J. Moore in “Coding Hospital Admissions From Other Sites of Service” [February 2003, page 19]. The article suggests that if a physician sees a patient in the office on a given day and then admits the patient to the hospital that same day, the physician can bill both the office visit (99201–99215) and the admit (99221–99223) as long as he or she waits to visit the patient in the hospital on the following date.

Some said this advice seems to contradict CPT, which says, “When the patient is admitted to the hospital as an inpatient in the course of an encounter in another site of service … all evaluation and management (E/M) services provided by that physician in conjunction with that admission are considered part of the initial hospital care when performed on the same date as the admission.” Their understanding of this passage is that if the physician does an office visit and admits the patient on the same day, then the office visit is considered part of the initial hospital care and is not separately billable, regardless of the date of service of the initial hospital visit.

Recognizing CPT’s distinction between initial hospital care and admission is the first step to understanding the CPT passage in question. The initial hospital care codes [99221–99223] are “used to report the first hospital inpatient encounter with the patient by the admitting physician,” according to CPT, and the descriptors for these codes state, “Initial hospital care, per day,” not “Hospital admission.”

According to staff at the Centers for Medicare & Medicaid Services, if the date of the initial hospital care coincides with the date of the admission, all related E/M services provided on that day are considered part of the initial hospital care, so only the initial hospital care codes should be submitted. This is because initial hospital care codes are “per day” services. That is, they encompass all of the related services that day. If the physician does not see the patient in the hospital on the date of the admission, services provided on the date of the admission should be billed using the E/M code that reflects the location in which they were delivered, such as 99201–99215. Then, if the physician sees the patient in the hospital on the date following the admission, an initial hospital care code can also be submitted (see the table).

CPT’s guidance would be clearer if the passage were revised to include the words in brackets below: “When the patient is admitted to the hospital as an inpatient in the course of an encounter in another site of service … all evaluation and management (E/M) services provided by that physician in conjunction with that admission are considered part of the initial hospital care when [the initial hospital care is] performed on the same date as the admission.”