Three codes introduced for observation; Provider Enrollment, Chain, and Ownership System enrollment update

February 25, 2011

The changes to the observation codes are highlighted.

Key Points

Q: Can you explain the changes to the observation codes?

The new codes are similar to the inpatient subsequent care codes in that they include an interval history. CPT describes an interval history as the history that "focuses on the period of time since the physician last performed an assessment of the patient" (CPT Assistant, January 2000, page 11). Code 99224 requires two of three components, including a problem-focused interval history, problem-focused exam, and medical decision-making that is straightforward or of low complexity. Code 99225 includes an expanded problem-focused interval history, an expanded problem-focused examination, and medical decision-making of moderate complexity. Code 99226 includes a detailed interval history, a detailed exam, and medical decision-making of high complexity.

The requirements for the new observation codes match the requirements for the subsequent hospital care codes. The new codes also have times associated with them that match the subsequent hospital care codes. The time for 99224 is 15 minutes, the time for 99225 is 25 minutes, and the time for 99226 is 35 minutes.

Time-based coding requires that more than half of the visit time be spent counseling and coordinating the patient's care. Documentation should reflect the full time of the visit, the time spent counseling and coordinating care, and a detailed description of the counseling given and the coordination of care needed.