ED Charge Coding for Non-Admitted Patients
Use the appropriate Emergency Department Evaluation and Management (E/M) code (CPT 99281-99285) based on the complexity of the clinical encounter, not the disposition decision. The fact that you did not admit the patient does not change the coding structure for ED services.
Correct Coding Approach
Select from CPT codes 99281 through 99285 based on the level of service provided during the ED encounter. 1 These codes reflect the complexity of history, physical examination, and medical decision-making required for the patient's evaluation, regardless of whether admission occurred.
Key Coding Principles
The disposition (admit vs. discharge) does not determine the E/M code level - you code based on what you actually did during the encounter, not where the patient went afterward 1
All three key components must be met for ED coding: history, physical examination, and medical decision-making 2
Code selection reflects the clinical work performed, including evaluation of potentially serious conditions that ultimately did not require admission 3
ED E/M Code Levels (CPT 99281-99285)
The five levels of ED service range from:
- 99281: Minimal complexity, straightforward problems
- 99282: Low complexity
- 99283: Moderate complexity (median code in many EDs) 3
- 99284: High complexity (also frequently used) 3
- 99285: Highest complexity, high-severity problems requiring urgent evaluation
Document all elements that support your chosen level, including the medical necessity for the evaluation, differential diagnoses considered, risk stratification performed, and clinical decision-making that led to safe discharge 3
Common Clinical Scenarios
Chest pain observation protocols with negative workup: Often code as 99284 or 99285 depending on initial risk assessment and testing performed 4
Syncope evaluation with intermediate risk factors: Typically 99283-99284 based on structured ED observation protocol complexity 4
Suspected serious conditions ultimately ruled out: Code reflects the complexity of excluding life-threatening diagnoses, not the final benign diagnosis 5
Critical Documentation Requirements
Your medical record must support the level of service billed through documentation of:
- Detailed history including pertinent positives and negatives 3
- Physical examination findings relevant to the presenting complaint 3
- Medical decision-making complexity, including differential diagnosis, data reviewed, and risk assessment 2
- Time spent is NOT the primary factor unless counseling dominates >50% of the encounter 2
Common Pitfalls to Avoid
Do not downcode simply because the patient was discharged - a complex evaluation that safely rules out serious pathology deserves appropriate coding 1
Do not use initial hospital care codes (99221-99223) unless you had a face-to-face encounter with the patient in the inpatient setting on the same date 1
Do not code based solely on time descriptors - the three key components (history, exam, medical decision-making) drive code selection 2
Avoid under-documenting high-complexity evaluations - patients with multiple comorbidities and high-risk presentations require thorough documentation to support higher-level codes 6