Coding the day prior to hospital discharge, dialysis and discharge on same date

Allowing a doctor to bill for a discharge the night before it occurs prevents a situation in which patients are occupying hospital beds solely in wait of a physician.

Key Points

Q: I frequently see patients in the hospital, and I am not able to conduct my rounds on the date they are discharged. Can I bill for my discharge summary even if it wasn't performed on the date of discharge?

This wording is a change from Medicare's previous rule, which said that the discharge summary had to be performed on the date the patient actually was discharged. Therefore, in situations in which a physician performs a discharge summary the night before the patient goes home, the discharge summary should be billed on the date it actually was performed, and Medicare will reimburse for the services.

If the patient has died, then only the physician who performed the death pronouncement can bill the face-to-face discharge-day management service, according to the Centers for Medicare and Medicaid Services (CMS). The date of the pronouncement should be the actual calendar date when the service was performed, even if the paperwork is delayed to a later date.

You may not report a discharge-day management service for a date after the patient leaves the hospital, however. CMS spells out that the physician actually must conduct a face-to-face visit to bill codes 99238 and 99239; the service is not just about completing the reams of paperwork, although that is part of the service. Medicare spells out that "paperwork involved in patient discharge day management services is paid through the pre-and post-service work of an E&M service." Therefore, don't try to bill separately just for the documentation portion of the service.


Q: I am an internal medicine physician and at times perform dialysis on the same day that I discharge a patient. Can I bill this service, and, if so, how?

A: Yes, you are able to bill for hemodialysis (90935) on the same date of service as a patient discharge (99238 or 99239). Here are a couple of things to remember, however:

First, make sure the patient is in "inpatient" status, place of service 21. Dialysis procedures during a hospitalization should be reported as appropriate (90935-90937, 90945-90947) and should not be billed for observation visits, place of service 22.

Second, the patient must have ESRD (such as ICD-9 585.6, end-stage renal disease). Physicians should use 90935 for hospital inpatients with ESRD or for outpatients who do not have ESRD (Part B News, December 2004).

The author is a compliance manager for Baptist Medical Associates in Louisville, Kentucky. Have a coding or managed care question for our experts? Send it to

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