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Established patient codes (99211-15) vs Subseq hosp codes (99231-33) for outpt stay

Question pertaining billing established patient codes versus subsequent hospital codes for an outpatient stay, POS 22:

Why we would use E/M 99212-99215 with POS 22 instead of the subsequent observation care codes 99224-99226? Is there an advantage of using one set of codes over another, or specific rules for why we would use one set over the other?

Thanks in advance for any advice–

Medical Billing and Coding Forum