NAMAS Webinar: FAQs for Auditing ED to Observation to Inpatient, 11/23/2021

Post here your questions regarding auditing ,coding, documentation, and compliance. Also, join in on the conversation- help your fellow auditors and compliance professionals in the industry.

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Below are the questions received during our recent webinar, FAQs for Auditing ED to Observation to Inpatient, originally presented on November 23, 2021. These questions have been answered by the webinar presenter, Stephanie Allard, CPC, CEMA, RHIT.

Question 1:
pt presents to ER, taken to cath lab (still outpatient/ER) gets admitted just after midnight by the cardiologists. POS for cath inpatient or outpatient?

Answer 1:
Place of service for the Cath procedure would be the one that the patient was in at the time of the procedure. So for example if they were not admitted to inpatient status until the next day then the day of the procedure would be POS 22 for outpatient.

Question 2:
We are experiencing ED bed holds where patients are staying in our ED for days due to transport issues and ICU bed/tertiary center unavailability. We are a CAH and are not able to take care of these patients on our unit (no ICU). Can we admit this patient as inpatient and keep them in our ED? If our hospitalists performs the H&P on this patient and rounds on them in the ED, do you see any concern billing an inpatient that is located in our ED?
Same scenario - if we kept the patient as an ED patient and they are here for 3 days waiting for transport to a tertiary center, can we bill a professional ED E/M fee for each date of service? What if they are assigned critical care time by the provider. Can this be charged each day? Thank you.

Answer 2:
This is going to depend on whether there are orders written for placement into observation or admission to inpatient status. If they are kept as ER then that would only count as one ER visit.
It would not be enough to just document or assign critical care, the note would have to support the critical status of the patient with monitoring and treatment to support specific organ systems and to stop further deterioration of the patient.

Question 3:
What do you do when the 1st day is Obs and the Physician bills as such. However the order changes to IP on the 2nd day till discharge. The Hospital claim shows IP for the entire stay but the Physician's OBS for day 1 claim gets denied due to the conflict with the hospital claim POS. Would it be appropriate to change/revise an order after a claim has been submitted to the payer and denied, but then we realize that the order was entered as OBS instead of IP in error. Can the order be revised and the claim resubmitted with the corrected admission status?
Answer 3:
If an amendment is required for one of the documents then a corrected claim could be submitted based on that supporting documentation.
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