Modifier -25 (significant, separately identifiable E/M service by the same physician on the day of a procedure) is used to distinguish visits from procedures on the same day.
It is not used to distinguish observation from a visit service on the same day.
Documentation and billing for observation stays has come under increased scrutiny from the OIG, though many hospitals have struggled with changing regulations and frequently updated guidance.
The role of the utilization review (UR) committee has changed as facilities transition from reporting condition code 44 for concurrent reviews to condition code W2 for post-discharge reviews.
