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Same specialty for Observation

I have a question regarding Observation services. I understand that only the admitting provider (or other providers under the same TIN and same specialty) should bill the Observation codes. All other providers should bill using the standard E&M code set. In our large group practice, the way the “Wards” schedule is, a patient could be admitted to Observation status by an Internal Medicine physician, and the next day the “doc of the day” for that ward is Family Medicine. Both are different specialties, but both are primary care. Can the physician for day 2 bill Observation due to being primary care, or does s/he have to use E&M codes due to different specialties?

Thanks in advance, Shelly

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