What Does Free COVID-19 Testing and Care Really Mean?

By Infinx
March 24, 2020

COVID-19 continues to impact on a global scale with over 390,000 confirmed cases worldwide, according to Johns Hopkins University.  While we don’t fully understand the economic impact overall, government agencies, payers, and the healthcare industry are already working to develop coding, billing, and collection strategies that will be fair to all during these uncertain times.

Those in charge seem to be mindful that in the era of high-deductible health plans and other cost-sharing arrangements, patients may end up facing insurmountable financial obligations when seeking care and treatment (especially those affected by layoffs and work stoppages).  The industry is acknowledging the problems arising from increased patient financial responsibility and are proactively addressing issues where possible.  

Free Testing Nationwide

As part of the Families First Coronavirus Response Act that signed into law on March 18, 2020, there are provisions to provide federal funding for testing all individuals, including uninsured patients, where it is indicated.  These provisions also cover the means of free coronavirus testing, including the cost of the provider and the physician’s office, urgent care center, or emergency room.  While this was much-needed legislation, to be fair, most insurance companies waived copays and co-insurances for testing back on March 6, 2020.

Billing for COVID-19 Care and Treatment

For care and treatment of COVID-19, most insurance companies are offering to waive the cost – however, some stipulations vary from company to company.  Further guidance is being provided through each company and is summarized here at America’s Health Insurance Plans website.  Specifics are fluid as the healthcare industry scrambles to take care of patients and expand to meet needs. However; many payers still require prior authorizations and reimbursement compliance to secure revenue.

One major concern for providers and hospitals is scaling up for the potential influx of patient care, but also the necessary coding and billing that follows, as well as staying up to speed with existing workflow, i.e., AR and denials management, etc.  Now is the time to consider third-party support during this crisis.

Telehealth Options are Being Encouraged

Already the Centers for Medicare and Medicaid (CMS) and many commercial payers have loosened the telehealth billing restrictions beginning on March 6, 2020, and lasting at least through the Public Health Emergency.  This allows patients with routine issues and follow-ups, such as medication refills and diabetes care, to continue self-isolating, as well as allowing providers to screen those patients exhibiting symptoms and triaging the best course of action before they go to an emergency room or physician’s office.

According to CMS, co-pays and deductibles will still apply as defined by the patient’s plan, but the HHS Office of Inspector General (OIG) is allowing hospitals and providers to opt out of charging or collecting them at their discretion.  At this point, Medicare is saying that it will pay at the full, contracted rate whether a copay is collected or not.

Coding for COVID-19 Testing, Exposure, and Treatment

To clarify, at this point, patients will not incur any financial responsibilities for co-pays or co-insurances. Still, labs, providers, and facilities can bill 100% of their contracted rate to the appropriate insurance entity using the following coding as appropriate:

  • For Coronavirus testing – American Medical Association (AMA) CPT coding guidelines issued the following new code effective March 13, 2020:
    • 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 (long descriptor).
  • According to the World Health Organization, the ICD-10-CM has been updated to reflect the following:
    • For Testing:
      • An emergency ICD-10 code of U07.1 is assigned to a disease diagnosis of COVID-19, confirmed by laboratory testing.
      • An emergency ICD-10 code of U07.2 is assigned to a clinical or epidemiological diagnosis of COVID-19, where laboratory confirmation is inconclusive or not available.
      • The title of U07 will be changed back to ‘codes for emergency use’
      • In ICD-11, currently under review, the code for the confirmed diagnosis of COVID-19, is RA01.0, and the code for the clinical diagnosis (suspected or probable) of COVID-19 is RA01.2.
    • For Exposure to COVID-19:
      •  Z03.818 (Encounter for observation for suspected exposure to other biological agents ruled out). Used for cases where there is a concern about possible exposure to COVID-19, but this is ruled out after evaluation.
      •  Z20.828 (Contact with and (suspected) exposure to other viral communicable diseases). Used for cases where there is actual exposure to someone who is confirmed to have COVID-19.
    • For Signs and Symptoms:
      • For patients presenting with any signs/symptoms (such as fever, etc.) and where a definitive diagnosis has not been established, assign the appropriate code(s) for each of the presenting signs and symptoms such as:
        • R05 (Cough)
        • R06.02 (Shortness of breath)
        • R50.9 (Fever, unspecified) 
    • For a pneumonia case confirmed as due to the 2019 novel coronavirus (COVID-19), assign codes:
      • J12.89 (Other viral pneumonia)
      • B97.29 (Other coronavirus as the cause of diseases classified elsewhere) 
    • For Bronchitis:
      • Acute bronchitis confirmed as due to COVID-19, assign codes:
      • J20.8 (Acute bronchitis)
      • B97.29 (Other Coronavirus as the cause of diseases classified elsewhere)
      • Bronchitis not otherwise specified (NOS) due to the COVID-19 should be coded using codes:
      • J40 (Bronchitis, not specified as acute or chronic)
      • B97.29 (Other Coronavirus as the cause of diseases classified elsewhere)
    • For Lower Respiratory Infection:
      • Assign the following codes if the COVID-19 is documented as being associated with a lower respiratory infection, not otherwise specified (NOS), or an acute respiratory infection, NOS:
        • J22 (Unspecified acute lower respiratory infection)
        • B97.29 (Other coronavirus as the cause of diseases classified elsewhere)
      • Assign the following codes if the COVID-19 is documented as being associated with a respiratory infection, NOS:
        • J98.8 (Other specified respiratory disorders)
        • B97.29 (Other Coronavirus as the cause of diseases classified elsewhere)
    • For ARDS due to COVID-19 should be assigned the codes:
      • J80 (Acute respiratory distress syndrome)
      • B97.29 (Other coronavirus as the cause of diseases classified elsewhere)
    • Other:
      • Diagnosis code B34.2 (Coronavirus infection, unspecified) would in general not be appropriate for the COVID-19, because the cases have universally been respiratory in nature, so the site would not be “unspecified.”
      • If the provider documents “suspected,” “possible” or “probable” COVID-19, do not assign code B97.29. Assign code(s) explaining the reason for encounter (such as fever, or Z20.828).

While the coverage mandate provisions of the Families First Act, require insurers and providers to ensure coverage, billing and payment systems need to be calibrated to bill/accept appropriate COVID-19 codes.  It also stipulates that patient cost sharing, i.e., co-pays, etc., should be waived starting immediately.

For those providers expecting to provide testing or services to uninsured patients, it’s recommended that they immediately register with HHS National Disaster Medical System (NDMS) to ensure reimbursement of their portion.

Over the next few months, policies and procedures will continue to change day by day, and Infinx will try to keep you updated as things evolve.  One thing is for sure, insurance providers are already estimating their costs to be well over $100 billion, and everyone should brace for anticipated increases to premiums and cost-sharing in 2021 and beyond.

We invite you to contact us about how your organization may benefit from COVID-19 coding and billing support moving forward.

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