Subsequent Observation Services

by  Codapedia
July 29th, 2016

CPT® released three new E/M services in 2011, to be used for the second and subsequent days that a patient is in observation status in the hospital. 

The codes are 99224--99226 and they are out of sequence in the CPT® book.  They require the same level of documentation as the three subsequent hospital visits.

99224 requires 2 of 3 of a problem focused interval history,  problem focused exam and straightforward or low medical decision making. The typical time is 15 minutes and it carries .82 RVUs.

99225 requires 2 of 3 of an expanded problem focused interval history, an expanded problem focused exam and moderate medical decision making. The typical time is 25 minutes and it carries 1.45 RVUs.

99226 requires 2 of 3 of a detailed interval history, a detailed exam and high complexity MDM. The typical time is 35 minutes and it carries 2.17 RVUs.

An interval history means that no past medical, family or social history is required.

CPT® is instructing all clinicians (admitting and other treating physicians) who see a patient in observation status to use these subsequent observation visit codes.  However, as of this writing, some CMS contractors are indicating that only the physician who admitted the patient to observation status should use these codes.  Physicians other than the admitting physician who see Medicare patients in observation status should bill with office/outpatient codes (9920199215).

As of Jan. 18, 2011, it looks like we’ll have different CPT® and CMS rules for using these new codes.


Subsequent Observation Services. (2016, July 29). Find-A-Code Articles. Retrieved from

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