2025 CPT Code 99217: Billing for Observation Discharge

 

CPT CODE 99217, 99218, 99219, 99220 - Observation codes

CPT code 99217 was previously used to bill observation discharge services. However, the AMA deleted this code in 2023. It is no longer valid in 2025.

Today, providers must use replacement codes like 99238, 99239, or 99234–99236. The correct code depends on how long the patient stayed and whether admission and discharge happened on the same day.

This article explains how to code observation discharges correctly in 2025. You’ll learn which codes to use, what payers expect, and how to avoid denials.

What Was CPT Code 99217?

In the past, CPT 99217 described discharge management from observation care. It included the final exam, discharge instructions, and documentation.

Physicians billed it on the CMS-1500 form for the day the patient left observation. But since 2023, the code is retired and not accepted by payers in 2025.

Why Was 99217 Deleted?

In 2023, CPT and CMS revised E/M services. They removed codes 99217–99220 and 99224–99226. Observation services were merged into standard inpatient E/M codes.

Instead of 99217, providers must now use:

  • 99238 – discharge, 30 minutes or less
  • 99239 – discharge, more than 30 minutes
  • 99234–99236 – same-day admission and discharge (if ≥ 8 hours)

How to Code Observation Discharge in 2025

Same-Day Discharge (≥ 8 Hours)

Use 99234–99236. These codes include both the admission and discharge.

Same-Day Discharge (< 8 Hours)

Report 99221–99223 for the admission only. No separate discharge code applies.

Multi-Day Observation

  • Admission day: 99221–99223
  • Subsequent day(s): 99231–99233
  • Discharge day: 99238 or 99239, based on time spent

Documentation Tips

To support billing, providers should document:

  • Total time spent on discharge day
  • Patient instructions and discharge summary
  • Admission and discharge times (for same-day stays)

Time is key for choosing 99238 vs 99239. Be sure to record minutes clearly.

Payer Guidance in 2025

All major payers, including Medicare and UHC, no longer accept 99217. Using it will trigger rejections or denials.

You can verify deleted codes on the CMS 2025 Physician Fee Schedule. Commercial payers now mirror these updates too.

Need help avoiding rejections? Read our post on CPT denial solutions.

Best Practices for Clean Claims

  • Delete 99217 from cheat sheets and EMRs
  • Train staff on discharge coding using updated codes
  • Use the correct POS: 22 or 23 for outpatient observation
  • Audit submitted claims monthly for outdated codes

Also, visit our UB-04 billing guide if you’re working on the hospital side.

FAQ

Is CPT 99217 still valid in 2025?

No. The AMA deleted it in 2023. All payers now reject claims with 99217.

Which codes replaced 99217?

Use 99238, 99239, or 99234–99236, based on time and scenario.

Do I need to document time?

Yes. Time is required for 99238 vs 99239. Record total discharge time clearly in the note.

Conclusion

CPT code 99217 is no longer billable in 2025. Use 99238, 99239, or 99234–99236 depending on the discharge situation. Always verify payer rules and update your systems to avoid denials.

For more help with E/M updates, visit cms1500claimbilling.com — your go-to resource for medical billing accuracy.

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