Reimbursement
$57.78
Threshold
30m
2026 Status
Active
What is CPT Code 99238?
CPT 99238 is defined as: Hospital inpatient or observation discharge day management; 30 minutes or less of total time spent by the physician or other qualified health care professional on the date of discharge.
This code is primarily used for E/M services. It falls under the category of Hospital Inpatient/Observation & Emergency Department and is valid for the 2026 calendar year according to the CMS Physician Fee Schedule.
2026 RVU Components
Relative Value Units (Non-Facility)
Work RVU
1.28
Physician Effort
PE (Non-Fac)
0.35
Practice Expense
Malpractice
0.1
Risk Factor
Total RVU
1.73
Note: [(Work RVU * Work GPCI) + (PE RVU * PE GPCI) + (MP RVU * MP GPCI)] * Conversion Factor
2026 CMS Policy Intelligence
discharge intensity
Recognizes the administrative and clinical burden of care transitions.
efficiency shield
Exempt from -2.5% efficiency cut.
tcm bridge
Discharge management (99238) is the prerequisite for subsequent TCM (99495-99496) billing.
Administrative Framework
Global Period
000
Place of Service
NCCI Exclusions
Operational Requirements
minimum time
No minimum for 99238; typically up to 30 minutes
staff type
Physician or other Qualified Health Care Professional (QHP)
frequency
Once per hospital stay
add on codes
care plan requirement
Final examination, discussion of hospital stay, instructions for continuing care, and preparation of discharge records/prescriptions.
Compliance Checklist
Audit Defense
No specific audit defense elements defined.
2026 Update
Verify that 'observation discharge' counts toward the hospital stay requirements for TCM if the patient was admitted under observation status.
Common Clinical Scenarios
CMS Eligibility: Patient ready for discharge to home or community setting. Final day of stay
Target Specialties & Utilization
Typical Clinical Indications (ICD-10)
Billing Differentiation
VS 99239
99238 is for 30 min or less; 99239 is for MORE than 30 minutes.
VS 99231
99231 is a stay-extension visit; 99238 is the terminal visit of the stay.
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