Disclaimer Regarding Guidance on Coding and Billing for COVID-19 Related Services. The guidance set forth herein regarding coding and billing for COVID-19 related services is for educational purposes only and is based upon the limited information available to Experity at the time of publication. Nothing contained herein shall be deemed to constitute a representation, warranty or guaranty of proper coding or payment for any particular medical claim.  The sole responsibility for proper coding and submission of any particular medical claim remains with you.  You should consult with a certified professional coder and an attorney licensed in your state for guidelines specific to your state, contracts and applicable payors.

This is a living document that will be updated as this situation evolves. This version is current to what we know on December 23, 2020 at 10:44 am.

Current COVID-19 Coding

For proper reimbursement and so patients do not receive a bill inappropriately, it is imperative that the coding be correct for all COVID-19 related services.

Diagnosis Coding

Effective January 1, 2021, there are new ICD-10 codes for reporting COVID-19 related diagnoses. These codes replace the existing codes we are using that are not as specific.

Condition	2020 ICD-10	2021 ICD-10
Encounter for screening for COVID-19	Z11.59	Z11.52
Contact with and (suspected) exposure to COVID-19	Z20.828	Z20.822
Personal history of COVID-19	Z86.19	Z86.16
Pneumonia due to coronavirus disease	U07.1 and J12.89	U07.1 and J12.82

There are two other new codes:

• M35.81 (Multisystem inflammatory syndrome (MIS)); and
• M35.89 (Other specified systemic involvement of connective tissue).

For patients diagnosed with (MIS) and COVID-19, report U07.1 with M35.81 as an additional diagnosis.

If MIS develops as a result of a previous COVID19 infection, report codes M35.81 and B94.8, (Sequelae of other specified infectious and parasitic diseases).

If the provider does not document that the MIS is due to the previous COVID-19 infection, report codes M35.81 and Z86.16.

If the patient has a known or suspected exposure to COVID-19, and no current COVID19 infection or history of COVID-19, report codes M35.81 and Z20.822.

Additional codes should be assigned for any associated complications of MIS.

Practices should start using these new ICD-10 codes with date of service January 1, 2021.

Current Coding for 2020

In the 2021 release of the Official ICD-10 Guidelines, the National Center for Health Statistics (NCHS) added instructions for coding the diagnoses for COVID-19 related services. The updated guidelines differ slightly from the previous interim guidance.

The official guidelines are updated annually on October 1st.

Positive Diagnosis of COVID-19

Only confirmed cases as documented by the provider or confirmed by test results should be coded with ICD U07.1, COVID-19. This code should be the primary diagnosis on the claim. Codes for any acute respiratory manifestations due to COVID-19 should be additional diagnoses (e.g., pneumonia). This is also the case for non-respiratory manifestations caused by COVID-19.

Diagnosis	ICD-10-CM
Pneumonia	U07.1 – COVID-19 J12.89 – Other viral pneumonia (J12.82 in 2021)
Acute Bronchitis	U07.1 – COVID-19 J20.8 – Acute bronchitis due to other specified organisms
Bronchitis, Not Otherwise Specified (NOS)	U07.1 – COVID-19 J40 – Bronchitis, not specified as acute or chronic
Lower Respiratory Infection, NOS, or Acute Respiratory Infection, NOS	U07.1 – COVID-19 J22 – Unspecified acute lower respiratory infection
Respiratory Infection, NOS	U07.1 – COVID-19 J98.8 – Other specified respiratory disorders
Acute Respiratory Distress Syndrome (ARDS)	U07.1 – COVID-19 J80 – Acute respiratory distress syndrome

 

No Definitive Diagnosis of COVID-19

Symptomatic Patients

Signs and symptoms without a definitive diagnosis should be reported with the code for each presenting problem. Some examples are:

R05 – Cough R06.02 – Shortness of breath R50.9 – Fever, unspecified R68.83 – Chills (without fever) R69.89 – Rigors M79.10 – Muscle pain R51 – Headache J02.9 – Sore throat R07.0 – Pain in throat R43.0 – Loss of smell

R43.9 – Loss of taste R19.7 – Diarrhea R11.0 – Nausea without vomiting R11.11 – Vomiting without nausea R11.2 – Nausea and vomiting R07.9 – Chest pain (central) R07.89 – Chest pain (anterior) R07.89 – Chest Pain (non-cardiac) R07.1 – Chest pain on breathing

This is not a comprehensive list. If the identified signs and symptoms is not on the list above, use the most appropriate ICD-10 available.

Report ICD Z20.828(Z20.822 in 2021), Contact with and (suspected) exposure to other viral communicable diseases,  in addition to the symptoms to clarify that the services are COVID-19 related.

Asymptomatic Patients

Asymptomatic patients with actual or suspected exposure should be coded with ICD Z20.828(Z20.822 in 2021).

Per the official guidelines, during the COVID-19 pandemic, a screening code is “generally not appropriate”. Even COVID-19 testing for preoperative testing should be coded as exposure, ICD Z20.828 (Z20.822 in 2021).

Additional Diagnoses

Diagnoses added to the guidelines are:

• History of COVID-19: Z86.19 (Z86.16 in 2021), Personal history of other infectious and parasitic diseases;
• Follow-up visits after COVID-19 has resolved: Z09, Encounter for follow-up examination after completed treatment for conditions other than malignant neoplasm, and Z86.19 (Z86.16 in 2021).
• Encounter for antibody testing: Z01.84, Encounter for antibody response examination.

Laboratory Testing

Combination Codes

With the start of flu season, manufacturers have created single tests that detect both influenza A and B plus COVID-19, and, in some cases, respiratory syncytial virus. There are two types: one includes the polymerase chain reaction (PCR) test, the other includes the antigen test.

• 87636 – Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) and influenza virus types A and B, multiplex amplified probe technique
• 87637 – Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), influenza virus types A and B, and respiratory syncytial virus, multiplex amplified probe technique

These CPTs were effective on 10/06/2020.

• 87428 – Infectious agent antigen detection by immunoassay technique, (e.g., enzyme immunoassay , enzyme-linked immunosorbent assay , fluorescence immunoassay , immunochemiluminometric assay ) qualitative or semiquantitave; severe acute respiratory syndrome coronavirus (e.g., SARS-CoV, SARS-CoV-2 [COVID-19]) and influenza virus types A and B

CPT 87428 was effective on 11/10/2020.

Single Codes

PCR Test

• U0002 – 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19) using any technique, multiple types or subtypes (includes all targets)
• 87635 – Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique

Most major payers are covering both 87635 and U0002 at the same rate. Medicare requires modifier QW (CLIA waived test).

Antibody Testing

Point-of-care tests should be reported with CPT 86328 (Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (e.g., reagent strip); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])).

Antigen Testing

• 87426 – Infectious agent antigen detection by immunoassay technique, (e.g., enzyme immunoassay , enzyme-linked immunosorbent assay , immunochemiluminometric assay ) qualitative or semiquantitative, multiple-step method; severed acute respiratory syn drome coronavirus (e.g., SARS-CoV, SARS-CoV-2 [COVID-19])

Medicare requires modifier QW (CLIA waived test).

CPT/Laboratory Test Crosswalk

All the tests listed have a waived status. Modifier QW should be appended when the insurance plan requires it.

Test	Manufacturer	CPT
Assure CoVID-19 IgG/IgM Rapid Test Device	Assure Tech. (Hangzhou Co., Ltd)	86328
CareStart COVID-19 Antigen Test	Access Bio, Inc.	87811
BinaxNOW COVID-19 Ag Card	Abbott Diagnostics Scarborough, Inc.	87811
LumiraDx SARS-CoV-2 Ag Test	LumiraDX UK Ltd.	87426
BD Veritor System for Rapid Detection of SARS-CoV-2	Becton, Dickinson and Company (BD)	87426
Sofia 2 SARS Antigen FIA	Quidel Corporation	87426
Cue COVID-19 Test	Cue Health Inc.	87635
ID NOW COVID-19	Abbott Diagnostics Scarborough, Inc.	87635
Xpert Xpress SARS-CoV-2 Test	Cepheid	87635
Accula SARS-Cov-2 Test	Mes Biotech Inc.	87635
cobas SARS-CoV-2 & Influenza A/B Nucleic Acid Test for use on the cobas Liat System	Roche Molecular Systems, Inc.	87636
BioFire Respiratory Panel 2.1-EZ (RP2.1-EZ)	BioFire Diagnostics, LLC	0202U
Xpert Xpress SARS-CoV-2/Flu/RSV	Cepheid	0241U
Sofia 2 Flu + SARS Antigen FIA	Quidel Corporation	87428

Specimen Collection

Specimen collection should only be reported when there is no other evaluation and management (E/M) code on the claim.

CMS approved reporting 99211 for specimen collection for new and established patients.

Counseling

On 07/30/2020, CMS announced how to report services when providers discuss the importance of self-isolation after the patient is tested and prior to the onset of symptoms. A Counseling Check List was also issued that outlines what topics to cover.

Providers should report the appropriate E/M code based on time when more than fifty percent of the face-to-face time is spent providing this counseling. If services are performed via telehealth, use the total time the provider personally spends furnishing the service on the day of the visit, face-to-face and non-face-to-face.

New E/M Code	Total Time	Established E/M Code	Total Time
99201	10 minutes	99211	5 minutes
99202	20 minutes	99212	10 minutes
99203	30 minutes	99213	15 minutes
99204	45 minutes	99214	25 minutes
99205	60 minutes	99215	40 minutes

In addition to what was covered during counseling, total time should be reported in minutes with the time spent in counseling (e.g., total time spent with the patient was 20 minutes with 15 minutes spent counseling on the need for self-isolation). In this example, CPT 99202 would be reported for a new patient and CPT 99213 for an established patient.

Modifiers for COVID-19 Testing-Related Services

The Families First Coronavirus Response Act waives cost-sharing under Medicare Part B (coinsurance and deductible amounts) for Medicare patients for COVID-19 testing-related services.

On April 7, 2020, CMS announced that E/M services that result in an order for or administration of a COVID-19 test, are related to furnishing or administering such a test or to the evaluation of an individual for purposes of determining the need for such a test should be billed with modifier CS for full payment. Patients should not be billed for these services.

This is effective for claims dated March 18, 2020 until the end of the Public Health Emergency (PHE).

Vaccine Coding

The American Medical Association (AMA) created a new code set for COVID-19 vaccine services. They can be found in a new Appendix Q, which will be updated as new vaccines become available

The structure is different from other vaccines. Each unique vaccine will have its own administration codes(s), depending on the number of doses. The manufacturer and name of the vaccine will be specifically listed in CPT, along with the National Drug Code (NDC).

Vaccine Administration	Manufacturer	Vaccine Code
0001A (1st dose) 0002A (2nd dose)	Pfizer, Inc.	91300
0011A (1st dose) 0012A (2nd dose)	Moderna, Inc.	91301
0021A (1st dose) 0022A (2nd dose)	AstraZeneca, Plc.	91302

Providers should not bill for the product if they received it for free. In that case, only the administration codes would be reported.

All vaccines are reported with diagnosis code Z23 (Encounter for immunization).

Telehealth (Audio and Visual)

Many prior restrictions have been relaxed for the duration of the PHE. Private payers have published effective periods.

Audio and Visual

CMS and many States have dictated that services be covered at the same rate as if the patient was in the clinic. Historically, CMS has covered these services at the lower facility rate due to decreased overhead.

CMS has instructed providers to bill with the same POS they would use if the patient had come to the office (i.e., 11 or 20). Modifier 95 (Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System) should be applied to indicate it was a telehealth service.

This coding ensures reimbursement at the appropriate non-facility rate. Claims submitted with POS 02 (Telehealth) will continue to be reimbursed at a lower rate.

These instructions are for payers that follow CMS guidelines. Instructions from private payers may vary.

Audio Only

Effective March 31, 2020, CMS began covering telephone calls. Many major private payers were already covering these services.

Documentation of time is used to support the level billed. Services can be reported for both new and established patients during the duration of the PHE.

• 99441 – Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion
• 99442 – Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion
• 99443 – Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion

The correct POS for these services is 11 (Office) or 20 (Urgent Care Facility) based on your contract.

Online Digital Evaluation and Management Services (E-Visits)

• 99421 – Online digital evaluation and management, service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes
• 99422 – Online digital evaluation and management, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes
• 99423 – Online digital evaluation and management, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes

This is for when a patient communicates with a provider via an EHR secure portal, secure e-mail or other digital application. It is for established patients but can be for a new problem. Services should be performed by a billable provider, not clinical staff.

Virtual Check-In

• G2012 – Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion

This is a virtual check-in or brief communication technology-based service where the provider may respond to the patient’s concern by telephone, audio/video, secure text messaging, e-mail or use of a patient portal.

Virtual check-in services can only be reported when the billing practice has an established relationship with the patient.

COVID-19 Facility Coding Scenarios

These examples are typical coding for these service. It may vary by payer. Specimen collection is included if billing another E/M.

Employer Work Site

Specimen Collection Only

• CPT: 99211
• POS: 11 or 20 per your contract
• Facility: Office address

Nursing Facility

Specimen Collection Only

• CPT: 99211
• POS: 11 or 20 per your contract
• Facility: Office address

Onsite E/M Visit and Specimen Collection

• CPT: 99304 – 99310
• POS: 32
• Facility: Nursing facility address

Telehealth E/M Visits and Specimen Collection

• CPT: 99201-99215
• Modifier: 95
• POS: 11 or 20 per your contract
• Facility: Office address

Skilled Nursing Facility

Specimen Collection Only

• CPT: 99211
• POS: 11 or 20 per your contract
• Facility: Office address

Onsite E/M Visit and Specimen Collection

• CPT: 99304 – 99310
• POS: 31
• Facility: Skilled nursing facility address

Telehealth E/M Visits and Specimen Collection

• CPT: 99201-99215
• Modifier: 95
• POS: 11 or 20 per your contract
• Facility: Office address

Assisted Living Facility

Specimen Collection Only

• CPT: 99211
• POS: 11 or 20 per your contract
• Facility: Office address

Onsite E/M Visit and Specimen Collection

• CPT: 99324 – 99337
• POS: 13
• Facility: Assisted living facility address

Telehealth E/M Visits and Specimen Collection

• CPT: 99201-99215
• Modifier: 95
• POS: 11 or 20 per your contract
• Facility: Office address

Custodial Care Facility

Specimen Collection Only

• CPT: 99211
• POS: 11 or 20 per your contract
• Facility: Office address

Onsite E/M Visit and Specimen Collection

• CPT: 99324 – 99337
• POS: 33
• Facility: Custodial care facility address

Telehealth E/M Visits and Specimen Collection

• CPT: 99201-99215
• Modifier: 95
• POS: 11 or 20 per your contract
• Facility: Office address 

Sources

CDC Current Instructions for Coding COVID-19 Related Services: ICD-10 Official Coding and Reporting Guidelines October 1, 2020 through September 30, 2021.

AMA Guidance for Reporting Code 87635: AMA Fact Sheet: Reporting Severe Acute Respiratory Syndrome Coronavirus (SARS-Cov-2) Laboratory Testing.

AMA Guidance for Reporting Code 86328: SARS-CoV-2 Serologic Laboratory Testing (Special Edition: April Update).

AMA Guidance for Reporting Code 0202U: Infectious Disease Testing for Bacterial or Virus Respiratory Tract Infection (Special Edition: May Update).

AMA Guidance for Reporting Code 87246, 0223U, 0224U: Severe Acute Respiratory Syndrome Coronavirus (SARS-CoV and SARS-CoV-2) Laboratory Testing (Special Edition: June Update).

AMA Guidance for Reporting Code 87636, 0241U: COVID-19 October Update.

AMA Guidance for Reporting Code 87428: COVID-19 November Update.

AMA Guidance for Coding Scenarios Unique to PHE: Special coding advice during COVID-19 public health emergency.