[Virginia] Observation service billing: review CMS requirements before

Before September 1, 2026: Billing team must review and update observation service billing practices to ensure compliance with CMS requirements. (1) Audit current observation billing workflows to identify cases where multiple observation codes are billed per patient visit or per calendar date. (2) Implement controls in billing software or claim submission process to prevent billing more than one initial observation service code per patient visit and per calendar date. (3) Educate all providers and clinical staff that only the physician who orders and oversees outpatient observation care may bill observation service codes; consultants and other practitioners must bill appropriate outpatient service codes instead. (4) Update billing guidelines and encounter forms to reflect the one-code-per-visit rule and practitioner restrictions. (5) Train billing team to validate practitioner credentials against observation orders before submission. Failure to comply will result in claim denials and potential overpayment recovery. Note: This applies to Anthem Medicare Advantage members in Virginia only; no balance billing of members is permitted under this update.