Discharge and Pronouncement of Death
Introduction to Discharge Services — Including Pronouncement of Death
Hospital discharge is one of the more detailed evaluation and management (E/M) encounters in Medicare, and it comes with several important billing rules. Under the Physician Fee Schedule, some services—especially those tied to a surgical global period—are already built into the global payment. That’s why knowing when a discharge service is truly billable, and what documentation must be present, is key for staying compliant.
Medicare defines Hospital Discharge Day Management (CPT 99238–99239) as a face‑to‑face service between the attending physician and the patient on the day of discharge. These codes may only be used when the attending physician personally evaluates the patient and completes the actual work of discharging them: the final exam, patient or caregiver instructions, and the preparation of the discharge summary.
Time Requirements for Discharge Services
Discharge codes are also time‑based, which means the attending physician must choose the correct code based on the total time they personally spend on discharge activities on the date of discharge.
- 99238 is used when 30 minutes or less are spent.
- 99239 is used when more than 30 minutes are spent.
Only the attending physician’s time counts in a teaching setting. Time spent by a resident working independently—or time spent on a day other than the discharge date—cannot be included. This ensures that the billed time truly reflects the physician’s own face‑to‑face work and decision‑making on the day the patient leaves the hospital. However, discharge services may be split/shared with an (APP) advance practice provider. This billing construct does allow time to be shared. The provider with more than half of the total time on the day of discharge reports the service.
Admission and Discharge Combination Codes
If a patient is both admitted and discharged on the same calendar date, the attending physician should use CPT codes 99234–99236, but only when all Medicare criteria for same‑day services are met. These codes combine the required work of admission and discharge into one service.
Physicians who are providing concurrent care, but not acting for the attending, cannot bill a discharge service. They must instead report a Subsequent Hospital Care code (99231–99233) for their final medically necessary visit. Medicare also reminds physicians that routine administrative work—such as paperwork and forms—is already included in the standard pre‑ and post‑service work of E/M codes.
Pronouncement of Death
A unique situation arises when the physician personally performs a pronouncement of death. In that scenario, Medicare instructs the physician to bill the appropriate Hospital Discharge Day Management code (99238 or 99239) for the face‑to‑face service. The date of service must match the actual calendar date the death was pronounced, even if the documentation is finished later.
Taken together, these rules highlight the importance of choosing the right code, capturing the required face‑to‑face elements, and documenting time and date accurately—especially when the encounter involves sensitive duties like confirming and documenting a patient’s death.
Resources:
Targeted Probe and Educate: Discharge Services