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Is there a requirement that the CPT codes submitted for payment to Medicare by the hospital and by the emergency physician be identical, or “match”?

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No. CMS has stated that Medicare does not expect a “high degree of correlation” of the CPT codes submitted by hospitals vs. those submitted by physicians. Since CPT codes were developed by the AMA to capture physician services and were never intended for capturing hospital services, Medicare recognizes that there may be significant differences in coding between the hospital and physician-even though the patient received services from both entities during the same outpatient encounter.

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