COVID-19: Coding and Billing Updates

• Beginning on December 10, 2020, the Centers for Medicare and Medicaid Services (CMS) initiated new codes for COVID-19 Monoclonal Antibodies and their administration during the public health emergency
• Beginning on January 1, 2021, CMS will implement 21 new ICD-10-PCS codes for vaccines and therapeutics, including FDA-approved baricitinib, currently used for rheumatoid arthritis (brand name Olumiant), and when used for inpatient treatment and in conjunction with remdesivir, as well as monoclonal antibody and immunomodulator treatments. Additionally, CMS assigned Medicare Severity Diagnosis-Related Groups (MS-DRGs) to new six ICD-10-PCS codes related to COVID-19 for inpatient care.
• For inpatient care, CMS has approved using the CPT code for vaccines and vaccine administration for all inpatients. Medicare Advantage participants should have claims submitted to Original Medicare for all vaccines and vaccine administration through 2021.
• On November 10, 2020, the AMA released new codes for the COVID-19 vaccine (91300 – Pfizer and 91301 – Moderna), as well as new administration codes (0001A, 0002A, 0011A, and 0012A).
• Effective October 28, 2020, CMS issued a rule stating that they will reimburse providers $28.39 for the administration of a single dose of COVID-19 vaccine. If the vaccine turns out to require multiple doses, CMS will pay $16.94 for the initial doses and $28.39 for the last dose of the series. Commercial insurance is expected to follow suit.
• CMS and commercial insurance plans will provide the vaccine for free to patients. In addition, state health agencies and others will provide the vaccine for free to uninsured patients.
• Effective October 23, 2020, Health and Human Services (HHS) has extended the public health emergency for 90 days or until January 23, 2021. This will also include a new round of $20 billion in support intended to cover ongoing pandemic-related expenses for providers.
• On October 7, 2020, the AMA published additional updated codes pertaining to COVID-19. The changes include several additions (Codes 87636, 87637, 87811) and one update (Code 87426).
  “Two of the newly approved codes report nucleic acid assays that allow a single test to simultaneously detect the novel coronavirus and a combination of common viral infectious agents, including influenza A/B and respiratory syncytial virus,” stated new AMA President Susan R. Bailey, M.D. “Concurrent detection promises to conserve important testing resources, allowing for ongoing surveillance of influenza while testing for the novel coronavirus.”
• On September 8, 2020, the AMA added two new codes for COVID-19 billing. The first code is CPT code 99072 and is intended to recognize additional supplies and clinical staff time that’s being used to contain and stop the coronavirus. The other code is 86413 intended to report quantitative measures of COVID-19 antibodies (further described below in the section entitled “COVID-19 Coding for Laboratory Testing”.

Through swift implementation at the onset of the COVID-19 public health emergency, several especially important things happened:

• Radical changes to healthcare delivery were accepted and implemented in real-time, including expansion of telehealth and virtual check-ins to include all locations (not just rural as previously specified)
• Copays and coinsurances were waived by CMS and most commercial insurances for COVID-19 testing and care for an interim period, and
• Updates were quickly approved and implemented to include codes for coronavirus testing and care in the CPT, DRG, and ICD-10-CM coding criteria and accepted universally by CMS and all commercial insurers. Codes continue to be updated as care expands to include booster vaccines, etc.

The AMA is issuing CPT codes for the use and administration of each new vaccine as they are submitted for approval from the Food and Drug Administration (FDA). More codes will follow with over 15 additional vaccines currently in development.

On Friday, August 10, 2020, the AMA added four new codes for SARS-CoV-2 testing as noted below.

On Friday, June 26, 2020, the AMA added a new code to specify billing of antigen tests performed on patients suspected of being infected with coronavirus. The AMA has already developed and approved CPT codes for other serological tests for COVID-19 antibodies, including 86328 and 86769 (below).

The CPT coding criteria was expanded, effective April 10, 2020, to specify reporting of anti-body testing with increased specificity.

As of January 1, 2021, all telehealth-related changes will be permanent.

Providers should bill new and established patients and their insurance payers for telehealth services for E/M including the office visit codes 99201-99205 for new patients and 99211–99215 for established patients. These codes should be appended with the modifier -95 to denote services provided at a remote location. These services will be paid at the current fee schedule and patients are not responsible for associated copays and co-deductibles when the service pertains to COVID-19.

CMS telehealth policy updates as of April 30, 2020:

• CMS is increasing payment for audio-only telephone E/M services (CPT codes 99441-99443) such that they are paid at the same rate as similar office and outpatient E/M visits, resulting in increased payments from $14-$41 to $46-$110. CMS believes that the resources required to furnish these services during the PHE are better captured by RVUs associated with level 2-4 established office/outpatient E/M visits. CMS is not increasing payment for CPT codes 98966-98968, which are intended for practitioners that cannot separately bill for E/M. This policy is retroactive to March 1, 2020.
• For telehealth services other than CPT codes 9944199443 and 98966-98968 (now added to the list of covered telehealth services), Medicare continues to require modalities that have both audio and video capabilities.
• During the COVID-19 public health emergency, rural and site limitations are removed. Telehealth services can now be provided regardless of where the enrollee is located geographically and type of site, which allows the home to be an eligible originating site. However, locations that are newly eligible will not receive a facility fee.
• CMS is forgoing its typical rulemaking process to add new services to the list of Medicare services that may be furnished via telehealth. Instead, CMS will add new telehealth services on a sub-regulatory basis to speed up the process of adding codes to the list.
• G0179, G0180, and G0181 are permanent and will continue post-PHE. The descriptors will be revised at a later date to include the non-physician practitioner specialties.

Like documenting an in-person encounter, charting must support the claim with history, a review of systems, consultative notes or any information used to make a medical determination, treatment plan, and care instructions. Additionally, consider it prudent to also include a statement if the service was provided through telehealth, including the location of both the patient and the provider and the names and roles of any other persons participating in the telehealth service.

The World Health Organization (WHO) had established a single ICD-10-CM code for COVID-19 that was to be effective October 1, 2020. This was changed to an effective date of April 1, 2020. Care delivered after April 1, 2020 should use this code for confirmed cases only:

This new code should be used for COVID-19 cases that are confirmed by diagnosis by a provider, have documentation of a positive COVID-19 test result, or a presumptive positive COVID-19 test result. A presumptive positive test result means an individual has tested positive for the virus at a local or state level but has not yet been confirmed by the CDC (something that is no longer required).

If “suspected”, “probable,” or “inconclusive” COVID-19 is documented, do not use U07.1. Assign a code(s) explaining the reason for the encounter (such as fever) or Z20.828 Contact with and suspected exposure to other viral communicable diseases.

Code U07.1 should be sequenced first when the patient meets the definition of primary or principal diagnosis Sequenced next should be the underlying diagnosis, such as J40 Bronchitis not otherwise specified (NOS) due to COVID-19:

Beginning on January 1, 2021, CMS will implement 21 new ICD-10-PCS codes for vaccines and therapeutics, including FDA-approved baricitinib, currently used for for rheumatoid arthritis (brand name Olumiant), and when used for inpatient treatment and in conjunction with remdesivir, as well as monoclonal antibody and immunomodulator treatments. These codes are as follows:

• XW013H6 Introduction of other new technology monoclonal antibody into subcutaneous tissue, percutaneous approach, new technology group 6
• XW013K6 Introduction of leronlimab monoclonal antibody into subcutaneous tissue, percutaneous approach, new technology group 6
• XW013S6 Introduction of COVID-19 vaccine dose 1 into subcutaneous tissue, percutaneous approach, new technology group 6
• XW013T6 Introduction of COVID-19 vaccine dose 2 into subcutaneous tissue, percutaneous approach, new technology group 6
• XW013U6 Introduction of COVID-19 vaccine into subcutaneous tissue, percutaneous approach, new technology group 6
• XW023S6 Introduction of COVID-19 vaccine dose 1 into muscle, percutaneous approach, new technology group 6
• XW023T6 Introduction of COVID-19 vaccine dose 2 into muscle, percutaneous approach, new technology group 6
• XW023U6 Introduction of COVID-19 vaccine into muscle, percutaneous approach, new technology group 6
• XW033E6 Introduction of etesevimab monoclonal antibody into peripheral vein, percutaneous approach, new technology group 6
• XW033F6 Introduction of bamlanivimab monoclonal antibody into peripheral vein, percutaneous approach, new technology group 6
• XW033G6 Introduction of REGN-COV2 monoclonal antibody into peripheral vein, percutaneous approach, new technology group 6
• XW033H6 Introduction of other new technology monoclonal antibody into peripheral vein, percutaneous approach, new technology group 6
• XW033L6 Introduction of CD24Fc immunomodulator into peripheral vein, percutaneous approach, new technology group 6
• XW043E6 Introduction of etesevimab monoclonal antibody into central vein, percutaneous approach, new technology group 6
• XW043F6 Introduction of bamlanivimab monoclonal antibody into central vein, percutaneous approach, new technology group 6
• XW043G6 Introduction of REGN-COV2 monoclonal antibody into central vein, percutaneous approach, new technology group 6
• XW043H6 Introduction of other new technology monoclonal antibody into central vein, percutaneous approach, new technology group 6
• XW043L6 Introduction of CD24Fc immunomodulator into central vein, percutaneous approach, new technology group 6
• XW07M6 Introduction of baricitinib into lower GI, via natural or artificial opening, new technology group 6
• XW0DXM6 Introduction of baricitinib into mouth and pharynx, external approach, new technology group 6
• XW0G7M6 Introduction of baricitinib into upper GI, via natural or artificial opening, new technology group 6

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.

CPT
American Medical Association, Press Release, AMA Announces Additional CPT Codes for COVID-19 Vaccines. December 17, 2020. https://www.ama-assn.org/press-center/press-releases/ama-announces-additional-cpt-codes-covid-19-vaccines

American Medical Association, CPT Assistant – Official Source for CPT Coding Guidance, Special Edition: April Update on SARS-CoV-2 Serologic Laboratory Testing
https://www.ama-assn.org/system/files/2020-04/cpt-assistant-guide-coronavirus-april-2020.pdf

American Medical Association, CPT Reporting for COVID-19 Testing and Care Chart
https://www.ama-assn.org/system/files/2020-04/cpt-reporting-covid-19-testing.pdf

American Medical Association, Special Coding Advice During COVID-19 Public Health Emergency, including coding scenarios defining best coding practices
https://www.ama-assn.org/system/files/2020-04/covid-19-coding-advice.pdf

American College of Physicians, Telehealth Coding and Billing During COVID-19, Updated April 16, 2020
https://www.acponline.org/practice-resources/covid-19-practice-management-resources/telehealth-coding-and-billing-during-covid-19

ICD-10-CM
American Academy of Professional Coders, ICD-10-CM Guidance
https://www.aapc.com/covid-19/

World Health Organization, Classifications, Emergency Use ICD Codes for COVID-19 Disease Outbreak
https://www.who.int/classifications/icd/covid19/en/

Coding and Billing Support
Infinx – Maximize Revenue in the Payment Lifecycle, Coding and Billing Support (Temporary or Long-Term)
https://www.infinx.com/