hospital discharge levels 99238 or 99239

We found in CPT Assistant (2006 Q&A) that the discharge level may be billed the
day prior to discharge if the discharge summary has been dictated the day before
discharge. Does Medicare allow this practice as well? As a critical access hospital
our patients may be transferred out early in the morning so the attending physician
does his summary and necessary transfer forms the night before. We have been
billing only a high subsequent hospital care code on the day prior to discharge and
no discharge level.

discharge

Yes, they do. A discharge visit is just that, if performed, bill on day performed. Of course, there would be no medical necessity for a hospital visit the next day.