Observation Status Order Compliance

I am the Manager of a team of Nurse Auditors who are responsible for charge integrity as well as verification and correction of admission status, after discharge. My organization has always looked at Observation status the same as Inpatient status in terms of NOT permitting an Emergency Department Physician to order a status of Observation without a co-signature from the Attending Physician. However, in reading the "HCPro Medicare Compliance Essentials Training Compendium" book, I have found, in Chapter 1, Medicare Requirements for Observation, page 67, the following statement....Observation services can be ordered by physicians authorized by state laws and hospital bylaws to admit patients or order outpatient tests. Physicians (e.g. ED Physicians) who can order outpatient tests MAY order Observation services even though they may NOT be authorized under hospital bylaws to admit patients for Inpatient status. This allows some flexibility for placement of patients in Observation......  Obviously, this will impact our current process and guidelines when verifying appropriate status.  Am I interpreting this correctly to say that an ED Physician MAY order Observation status WITHOUT the co-signature of an Attending Physician?          


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