ED observation billing

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Boatswain2PA

Physician Assistant
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I've always documented an ED Obs note for patients I am purposefully keeping in the ED for an extended period of time to observe/re-examine/re-test them to determine admission or discharge.

Management now telling me that I can obs just about everyone who is in the ED for >3 hours. If it takes 3 hours to get labs/rads back, then I count that time as the 3 hour observation and create an obs note. I don't have to purposefully "place" the pt in observation specifically to recheck something.

Is that what you do? Doesn't seem right to me.....

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I've always documented an ED Obs note for patients I am purposefully keeping in the ED for an extended period of time to observe/re-examine/re-test them to determine admission or discharge.

Management now telling me that I can obs just about everyone who is in the ED for >3 hours. If it takes 3 hours to get labs/rads back, then I count that time as the 3 hour observation and create an obs note. I don't have to purposefully "place" the pt in observation specifically to recheck something.

Is that what you do? Doesn't seem right to me.....

This is wrong. Obs billing is used to make clinical decision. Mostly post overdose, alcohol, transfusions that are DCd. Sometimes delta trops. It's really only used in cases that you're actually obsing to determine your dispo. Not just because labs take 3 hrs

It also depends on their insurance. A lot, such as medicaid actually requires 8hrs to bill for obs, etc.

Doing it on anyone there for three hours is an excellent way to get your ass in trouble. Or whoever signs your charts rather.
 
This is wrong. Obs billing is used to make clinical decision. Mostly post overdose, alcohol, transfusions that are DCd. Sometimes delta trops. It's really only used in cases that you're actually obsing to determine your dispo. Not just because labs take 3 hrs

It also depends on their insurance. A lot, such as medicaid actually requires 8hrs to bill for obs, etc.

Doing it on anyone there for three hours is an excellent way to get your ass in trouble. Or whoever signs your charts rather.
That is my take on it too.

Except for the "OR" whoever signs my charts. It would be my responsibility first, and of course some liability on them as well (because that's the f'd up system we work in).

Thanks.
 
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I've always documented an ED Obs note for patients I am purposefully keeping in the ED for an extended period of time to observe/re-examine/re-test them to determine admission or discharge.

Management now telling me that I can obs just about everyone who is in the ED for >3 hours. If it takes 3 hours to get labs/rads back, then I count that time as the 3 hour observation and create an obs note. I don't have to purposefully "place" the pt in observation specifically to recheck something.

Is that what you do? Doesn't seem right to me.....

So you create an initial note when you see the patient, and then if three hours pass and they are not dispoed, you create an Obs note?
 
This is completely illegitimate and Obs is used for ongoing pt care and management.

Its not waiting on Labs/CT, otherwise some of my site would be 100% Obs. Management, cough CMG, is ridiculous.
 
So you create an initial note when you see the patient, and then if three hours pass and they are not dispoed, you create an Obs note?
Management wants the initial note, and then create the Obs note upon disposition if it's been>3 hours.


Thanks to all for confirming what I thought I knew.
 
I could be wrong, but I think you need to put an observation admission order in to bill for observation status.

Second, I feel like this puts you at risk of an audit if your group is billing for obs in these cases. Again, I could be completely wrong.
 
Sounds like CMGs are running out of ways to make money.

Billing for Observation means you PUT then in Obs AND Put in Obs orders AND billed separately from the ER bill. Its not some add on code like critical care.

Whoever is making this decision is ill-informed or just downright illegal.
 
Maybe obs rules have changed but I thought you had to have >8 hour stay in order to qualify for obs. And that's 8 hrs after your status changes from an emergency department to an observation stay. Maybe OPs management wants to prospectively have the note so if they stay >8 hours they can bill? Maybe they're going to bill on >3 hrs and hope they don't get caught? Or it could just be a sneaky way of getting people to document a re-exam for medicolegal/quality purposes?
 
My understanding is observation is minimum 6 hours, not 8
 
I could be wrong, but I think you need to put an observation admission order in to bill for observation status.

Second, I feel like this puts you at risk of an audit if your group is billing for obs in these cases. Again, I could be completely wrong.

Maybe obs rules have changed but I thought you had to have >8 hour stay in order to qualify for obs. And that's 8 hrs after your status changes from an emergency department to an observation stay. Maybe OPs management wants to prospectively have the note so if they stay >8 hours they can bill? Maybe they're going to bill on >3 hrs and hope they don't get caught? Or it could just be a sneaky way of getting people to document a re-exam for medicolegal/quality purposes?

My understanding is observation is minimum 6 hours, not 8
Nope. You can do an obs note in your chart and never change the patients department status and can bill for it. It's actually quite a bit of reimbursemnt. It also depends on the insurance of the patient. Some require little as 2 hrs some up to 8 hours. I personally never bother with a note under 4hrs. It's heavily underutilized by EM docs, but definitely going to be the "next thing". Probably especiallly on the CMG front. The reason why is obs in the ED is much cheaper than a hospital stay.
 
I think it makes sense to have an ED obs note and billing if we are truly keeping someone in the ED for a few more hours to determine whether they need to go home or be admitted. I've been told we can't bill for ED Obs if they are admitted to the hospital under the Observation, but we can if they are sent home or admitted inpatient, and that makes sense as well.
 
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There is no strict time for Obs but you will be marked obsing someone while not doing any treatment. In Obs you are supposed to do Obs notes and if you note says, "Pt in Obs waiting for CT"? How can any clinician in their right mind chart that?
 
There is no strict time for Obs but you will be marked obsing someone while not doing any treatment. In Obs you are supposed to do Obs notes and if you note says, "Pt in Obs waiting for CT"? How can any clinician in their right mind chart that?

No, there's strict criteria for an obs note, but it's very simple. You can macro an obs note and it takes 10 seconds to fill in blanks. As said above you can not do obs if you're waiting for labs/ct. That's not obs.

A guy comes in drunk af, you don't do anything and you discharge him 8hrs later clinically sober. That's 8hrs of obs.

Sure, the guy likely doesn't have insurance anyway, but in the off chance he does or if you group hopefully pools RVUs for reimbursement... Then boom.
 
No, there's strict criteria for an obs note, but it's very simple. You can macro an obs note and it takes 10 seconds to fill in blanks. As said above you can not do obs if you're waiting for labs/ct. That's not obs.

A guy comes in drunk af, you don't do anything and you discharge him 8hrs later clinically sober. That's 8hrs of obs.

Sure, the guy likely doesn't have insurance anyway, but in the off chance he does or if you group hopefully pools RVUs for reimbursement... Then boom.
What's the required text?
 
Some interesting replies in this thread.

The OP is correct, what is being asked is sketchy and not how I understand observation to be used.

A few points->
(1) Time. The classic teaching is that it demands at least 8hrs. This is true for SAME-DAY observation when billing MEDICARE. If you cross midnight, thats two different days, and thus two different codes, and thus you don’t need 8hr. As well, other payers set their own policies, and I understand some will use 4-6hr. CPT definitions for observation DIFFER from CMS demands for Medicare payment.
(2) Observation, philosophically, is using an extended period of time to treat and observe the patient to decide if a lengthy inpatient stay is required, or if you can send them home. It is NOT time waiting for a test that is only available certain times of day, or waiting room time, or ED boarding time waiting for an inpatient bed that is inevitable. ACEP gives this handy example list:
“OBSERVATION:
  1. Intoxicated head injury patient observed to r/o significant injury.
  2. Questionable overdose observed to r/o significant toxicity.
  3. Chest pain with repeat testing to rule out ischemia.
  4. Dehydrated patient observed to administer fluids and ability to retain oral liquids.
  5. Kidney stone observed to repeat x-rays and/or adequate pain control for possible admission.
  6. Asthmatic requiring repeat treatments and serial exams to determine response to treatment.
  7. Headache patients requiring repeat treatments and serial exams to determine if they improve with treatment.
  8. Abdominal pain patients requiring serial exams to determine response to treatment.
Examples of cases where coding Observation services would generally not be indicated:

  1. Patient waiting on in-patient admission bed.
  2. Patient awaiting ride home.
  3. Lengthy procedures (laceration repair, reductions, etc…).
  4. Broken CT/MRI/Ultrasound/… equipment.
  5. Busy emergency department and delay in assessments due to volume or staffing.
  6. Waiting for consultant. “
  7. A personal pet peeve—> ED OBSV at 10pm so they can get a lower extremity U/S to r/o DVT @0800 the next AM. Nope. Not observation.
(3) The requirements to bill for observation differ for professional and facility billing. The hospital requirements (especially for Medicare) are more arduous, and require:
A. A physician order to place in observation
B. An ED visit code from that day (we are speaking of ED observation specifically)
C. 8hr of time elapsing, starting with the order A.**
D. While actively being cared for in observation, care must be documented in the medical record with an order for observation, admission notes, progress notes, and discharge instructions all of which are dated, timed, written, and signed by the physician or midlevel if applicable.
E. The medical record must include documentation that the physician used "risk stratification" criteria to determine that the patient would benefit from observation care.

**you can’t count time the patient is off unit without an RN, say in radiology for hours not being monitored, having a prolonged test (HIDA). You also can’t count time the patient is sitting in the room after being discharged from OBS, say waiting 90min for a BLS ambulance back to a nursing home.
 
could I get an example macro to use? My site is switching to RVU literally next month and we have a decent chunk of serious alcoholics with a case of the trip-and-fallsies who could definitely benefit (me) from being put into obs status.
 
Pt placed into observation status at (time) for (condition requiring obs). Family history (is/is not) significant for this encounter. Pt discharged from observation at (time) and (admitted to inpatient status/discharged to home). Total observation time is (xx) hours.
 
Do you just add this at the end of your regular note?
Yes, often with a little MDM after about why was d/c home.

You have to specify family history for some reason. I used to think you had to document a reexamination l but was recently told you dont have to do that. Not sure if I was just wrong, or it changed.
 
I work in a SDG that bills obs frequently. Our coder and biller request that we use obs for stays longer than 4 hours for medicare criteria. Other payers require more time, but we don't worry about this part as the physician seeing the patient. They get a progress note (one liner with a time evaluated) for each observation day and a obs DC note in addition to the initial ED note. Usually 3 notes. Across midnight gets a 4th. The time in and out of obs must be documented in the note. We do use an EMR order to timestamp this. The common mistake made is in not obtaining family history (required for obs billing). We have been advised by the coding company that obs criteria is met for "diagnostic uncertainty" or "therapeutic intensity." We put a line in the initial note that says something like "...admitted to obs status at x time for diagnostic uncertainty, in order to perform neurologic and cardiopulmonary monitoring for return to clinical sobriety."

Very commonly used to monitor the known intoxicant for whom we don't get labs. Also handy for the kidney injury or electrolyte dysfunction that you plan to street after some (hours of) fluid management. We will also commonly use this for the dubious TIA/stroke workup that neuro thinks can be DCed after an MRI. What I don't see though is the data for which obs claims are paid so take with a grain of salt.
 
Is an order for observation admission required to be entered in the EMR prior to billing?
NO there is no order. This is akin to billing for critical care. You can bill obs withouit a change in the patients “ED” status. Every billing company has the rules they like so make sure you know. Keep in mind if a patient stays over a midnight the medicare 8 hour rule is out the window.
 
I'm not in EM, but what in the world is the rationale for why one must document a family history WITHIN the obs note as described? When will that (nearly) ever have relevance to why the patient is undergoing obs in the first place?
 
I'm not in EM, but what in the world is the rationale for why one must document a family history WITHIN the obs note as described? When will that (nearly) ever have relevance to why the patient is undergoing obs in the first place?
There is no rationale. Someone makes the rules. We just play the game.
 
I'm not in EM, but what in the world is the rationale for why one must document a family history WITHIN the obs note as described? When will that (nearly) ever have relevance to why the patient is undergoing obs in the first place?

It's all a game to avoid payment. They make us document irrelevant things like ROS, FH, SocH in order to downcode and reduce payment if you miss one of the required elements.
 
From experience, I don't sense Obs pays much on the professional side. The big bucks is on the facility side.
 
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