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Anthem BCBSMedicare Advantage · Billing Codes · Claims & Billing · GA · Emergency Medicine, Internal Medicine, General PracticeHigh impact

[Georgia] Observation service billing: review CMS requirements before

Act
by Aug 31, 2026
Effective date
Sep 1, 2026
Identified
Aug 3, 2026

Summary

Effective September 1, 2026, Anthem Blue Cross and Blue Shield (Georgia) is updating observation service billing requirements to align with CMS guidance for claims billed under POS codes 19, 22, or 23. Key restrictions include: only one initial observation service code per patient visit, one observation code per calendar date per billing practitioner, and only the ordering/overseeing physician may bill observation codes—other practitioners must use appropriate outpatient service codes instead.

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What to do

by Aug 31, 2026 · 8 steps
01Billing team must review and update observation service billing practices to comply with CMS requirements.
02Configure billing system to prevent submission of multiple initial observation codes per patient visit.
03Implement control to block multiple observation service codes per calendar date per practitioner.
04Update provider education and billing guidelines to clarify that only the physician ordering and overseeing observation care may bill observation codes.
05Train providers and billing staff that consulting physicians and other practitioners during observation stays must bill appropriate outpatient service codes instead.
06Audit recent claims (past 6 months) for observation services under POS 19, 22, or 23 to identify potential billing violations.
07Ensure all participating providers understand the prohibition on balance billing members under this update.
08All claims submitted after September 1, 2026 that violate these requirements will be subject to denial and potential recovery.

Original notice

[Georgia] Observation service billing: review CMS requirements before
providernews.anthem.com · Always check the source before changing claims.
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