Observation Services Policy
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Governance of reimbursement, billing and coding for hospital observation services provided to Blue Cross and Blue Shield of Texas members across all facilities; affects providers submitting claims for observation care.
No material clinical or coverage changes in this revision.
Observation Services Coverage and Billing Criteria
Observation coverage and billing criteria
Covered when ALL of the following are met:
ALL of the following
- Observation services are eligible for reimbursement only when provided under a physician's order or the order of an authorized practitioner who may admit members and order outpatient testing; services must be member-specific and not part of standard facility protocol.
- Observation care is appropriate for short-term evaluation, treatment, or monitoring (including repeat testing or re-evaluation) as an alternative to inpatient hospitalization when the member does not meet inpatient level of care.
- Observation time must be documented in the medical record from the time the qualified provider's order initiates observation care through completion/discharge; care provided before the order or after an inpatient admission order is excluded from observation time.
- Supporting documentation must include the attending physician's order for observation with clock time (or nurse's observation admission note with time), physician admission/progress notes, diagnostic/ancillary test reports, admission progress notes with clock time, and discharge notes with clock time; member must be under the care of a physician or qualified nonphysician practitioner during observation care.
ALL of the following
- If the member converts to inpatient status, the provider should submit an inpatient authorization request as required; all observation services provided are included on the inpatient claim and observation dates should be reflected on the UB-04 FROM date per policy example.
ALL of the following
Billing requirements (ONE of):
- Hospitals must bill HCPCS G0378 for facility observation service per hour with revenue code 0762 and units equal to the number of observation hours; only one line of revenue code 0762 is allowed on the UB-04 for observation status.
Facility and E/M Codes for Observation
| G0378 | Hospital observation service, per hour |
| G0379 | Direct admission of observation care after ambulatory/community practitioner without ER or outpatient visit same day |
| 99221-99223 | Initial hospital inpatient or observation care E/M codes |
| 99231-99233 | Subsequent hospital inpatient or observation care E/M codes |
| 99234-99236 | Observation care and inpatient admission on same date E/M codes |
| 99238-99239 | Hospital discharge day management |
Provider Responsibilities and Prior Authorization
Prior authorization for observation conversion
Observation does not require prior authorization. If a member converts from observation to inpatient, the provider should submit an inpatient authorization request because the admission may require prior authorization; all observation services provided are included on the inpatient claim when the member is subsequently admitted as an inpatient.
- If conversion to inpatient occurs, submit an inpatient authorization request per policy.
- When a discharged-from-observation member is later admitted as inpatient, include all observation services on the inpatient claim and use the inpatient FROM date on the UB-04 as instructed.
Definitions — Observation Services and Time
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