Billing Critical Care and Discharge On Same Calendar Date?

Can I bill a critical care code and a discharge code on the same day?   That's a question a lot of folks finding The Happy Hospitalist are asking themselves.  I am a hospitalist with over ten years of clinical experience and years of research in evaluation and management (E/M) medicine.   I have a very short answer and one that should lay to rest any question about what code the physician should choose when they provide critical care on the date of discharge. On page 3 of 9 in  CMS document MM6740, we are told In all cases, physicians will bill the available code that most appropriately describes the level of the services provided. That means, if you provide critical care you should bill for critical care, regardless of whether that service was provided on the day of admission or the day of discharge. Yes, I believe the physician can and should bill for critical care even if they discharged the patient on the same date as the critical care service was provided.  But can they also bill a discharge code?  I do not believe they can. Even though CMS tells us we should bill the available code that most appropriately describes the level of services provided, I believe their rules disallow both codes on the same calendar date.   As such, physicians would be better off billing for their critical care services and not the discharge codes in these situations.   My exhaustive research on this issue failed to disway my opinion on this matter...
Source: The Happy Hospitalist - Category: Internists and Doctors of Medicine Authors: Source Type: blogs