Coding During the Public Health Emergency

Introduction

As you navigate the day-to-day uncertainties of providing patient care during the COVID-19 outbreak, ensuring appropriate coding may not be top of mind for your clinicians. The following information and guidelines will help you answer any E/M coding questions and communicate best practices with your staff to keep your clinic as healthy as your patients.

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 August 28, at 9:20 am.

COVID-19 Coding & Guidance

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

In the 2021 release of the Official ICD-10 Guidelines, the National Center for Health Statistics (NCHS) has 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
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:

  • R05Cough
  • R06.02Shortness of breath
  • R50.9Fever, unspecified
  • R68.83 Chills (without fever)
  • R69.89 – Rigors
  • M79.10Muscle pain
  • R51Headache
  • J02.9Sore throat
  • R07.0Pain in throat
  • R43.0Loss of smell
  • R43.9Loss of taste
  • R19.7Diarrhea
  • R11.0Nausea without vomiting
  • R11.11Vomiting without nausea
  • R11.2 Nausea and vomiting
  • R07.9Chest pain (central)
  • R07.89Chest pain (anterior)
  • R07.89Chest Pain (non-cardiac)
  • R07.1Chest 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, 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.

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.

Additional Diagnoses

Diagnoses added to the guidelines are:

  • History of COVID-19: 19, 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 19.
  • Encounter for antibody testing: 84, Encounter for antibody response examination.

No new ICD codes were created for reporting COVID-19.

Laboratory Testing

Virus Detection

Both the Centers for Medicare & Medicaid Services (CMS) and the American Medical Association (AMA) issued new procedure codes for testing for COVID-19.

  • 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 ), amplified probe technique

Most major payers are covering both 87635 and U0002 at the same rate. Medicare requires modifier QW (CLIA waived test) on these codes effective DOS 03/20/2020.

Antibody Testing

On April 10, 2020, the CPT Editorial Panel held an emergency meeting and approved new CPTs for antibody testing. The codes became effective on the same date.

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 )).

For more information, see our article, COVID-19: What you need to know about antibody testing.

Antigen Testing

On June 25, 2020, the CPT Editorial Panel held a third emergency meeting to approve the new CPT 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 ) for antigen testing.

This code is effective on the same date. Prior to this date, providers should use CPT U0002 per CMS guidance.

Medicare requires modifier QW (CLIA waived test) on CPT 87426 to identify that the test can be performed in a facility with a CLIA Certificate of Waiver.

Proprietary Lab Analysis (PLA) Codes

Three PLA codes have also been approved. PLA codes are specific to the manufacturer.

  • 0220U – BioFire® Respiratory Panel 2.1 (RP2.1), BioFire® Diagnostics, BioFire® Diagnostics, LLC
  • 0223UQIAstat-Dx Respiratory SARS-CoV-2 Panel, QIAGEN Sciences, QIAGEN GMbH
  • 0224UCOVID-19 Antibody Test, Mt Sinai, Mount Sinai Laboratory

Specimen Collection

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

In the interim final rule published on 04/30/2020, 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).

The following instructions apply to all services regardless of diagnosis

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.

New Instructions for Telehealth Coding Effective March 31, 2020

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. In addition, on April 30, 2020, CMS announced they were increasing payments for telephone calls to match payments for similar office and outpatient visits retroactive to March 1, 2020.

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.

Other Services

There are other virtual services that may be more appropriate to clearly identify the services performed. Coverage will vary by payer.

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 the physician or NPP, 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

Employer Work Site

Specimen Collection Only

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

This is typical coding for this service. It may vary by payer.

Nursing Facility

Specimen Collection Only

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

This is typical coding for this service. It may vary by payer.

Onsite E/M Visit and Specimen Collection

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

Specimen collection is included in the E/M.

Telehealth E/M Visits and Specimen Collection

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

This is typical coding for this service. It may vary by payer. Specimen collection is included in the E/M.

Skilled Nursing Facility

Specimen Collection Only

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

This is typical coding for this service. It may vary by payer.

Onsite E/M Visit and Specimen Collection

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

Specimen collection is included in the E/M.

Telehealth E/M Visits and Specimen Collection

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

This is typical coding for this service. It may vary by payer. Specimen collection is included in the E/M.

Assisted Living Facility

Specimen Collection Only

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

This is typical coding for this service. It may vary by payer.

Onsite E/M Visit and Specimen Collection

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

Specimen collection is included in the E/M.

Telehealth E/M Visits and Specimen Collection
  • CPT: 99201-99215
  • Modifier: 95
  • POS: 11 or 20 per your contract
  • Facility: Office address

This is typical coding for this service. It may vary by payer. Specimen collection is included in the E/M.

Custodial Care Facility

Specimen Collection Only

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

This is typical coding for this service. It may vary by payer.

Onsite E/M Visit and Specimen Collection

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

Specimen collection is included in the E/M.

Telehealth E/M Visits and Specimen Collection

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

This is typical coding for this service. It may vary by payer. Specimen collection is included in the E/M.

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

Download the Quick COVID-19 Coding Guide