CMS Posts Updated FAQs for Condition Code 44

The Centers for Medicare and Medicaid Services has posted two updated answers in its frequently asked questions section of its Web site related to Condition Code 44 (Inpatient admission changed to outpatient).

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Here are the two questions and a summary of the updated answers:

May a hospital change a patient’s status using Condition Code 44 when a physician changes the patient’s status without utilization review (UR) committee involvement?

  • No, the policy for changing a patient’s status using Condition Code 44 requires that the determination to change a patient’s status be made by the UR committee with physician concurrence. The hospital may not change a patient’s status from inpatient to outpatient without UR committee involvement. The conditions for the use of Condition Code 44 require physician concurrence with the UR committee decision.

How should the hospital report observation services when the patient’s status is changed from inpatient to outpatient using Condition Code 44? May the hospital report observation services from the beginning of the hospital outpatient encounter?

  • The use of Condition Code 44 pertains to the entire patient encounter, the patient’s status and the hospital bill type submitted. Medicare does not recognize a separate patient status called “observation;” all hospital patients are either inpatients (if they are admitted as inpatients on the order of a physician) or outpatients (registered by the hospital as outpatients). When Condition Code 44 is appropriately used, the hospital reports on the outpatient bill the services that were ordered and provided to the patient for the entire patient encounter. Reporting of individual HCPCS codes on an outpatient claim must be consistent with all applicable instructions and CMS guidance.

Review the complete answers for Condition Code 44.

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