COVID-19 Coding and Billing Resource Center

During this uncertain time, the team at TruCode wants to make sure you have the latest information regarding billing and coding changes related to the COVID-19 pandemic. Below is a list of links to helpful resources, as well as a Q&A section related to recent changes. We will update this webpage as new information becomes available. The most recent information will be posted first under each category, so you can easily identify new content. Be assured that we will continue to update the TruCode Encoder and Encoder Essentials to assist you in correct and accurate coding. We appreciate you and your team very much! 

Addition of the QW modifier to Healthcare Common Procedure Coding System (HCPCS) code U0002 and 87635 (4/24/20)

https://www.cms.gov/files/document/r10066otn.pdf

ICD-10-CM Coding for COVID-19 webinar recording presented by the AHA (3/12/20)

http://sponsored.aha.org/HFC-GEN2020CodingWebinarPromotionCOVID_Mar122020-CodingWebinarOn-DemandReplay.html

New Codes

New CPT Codes have been created that streamline the novel coronavirus testing currently available in the U.S. market (updated 10/6/20)

https://www.ama-assn.org/practice-management/cpt/covid-19-coding-and-guidance

CPT Assist Special Editions (updated 9/8/20)

https://www.ama-assn.org/practice-management/cpt/covid-19-coding-and-guidance

Quick reference flowchart that outlines CPT reporting for COVID-19 Testing (5/6/20)

https://www.ama-assn.org/system/files/2020-03/cpt-reporting-covid-19-testing.pdf

CMS Increases Medicare Payment for High-Production Coronavirus Lab Tests (4/15/20)

https://www.cms.gov/newsroom/press-releases/cms-increases-medicare-payment-high-production-coronavirus-lab-tests-0

Federal Register Regulatory Updates (4/6/20)

https://www.govinfo.gov/content/pkg/FR-2020-04-06/pdf/2020-06990.pdf

New CPT Codes for Serologic Laboratory Testing (April 2020)

https://www.ama-assn.org/system/files/2020-04/cpt-assistant-guide-coronavirus-april-2020.pdf

CDC Announced ICD-10-CM Addenda (4/1/20)

https://www.cdc.gov/nchs/data/icd/ICD-10-CM-April-1-2020-addenda.pdf

Check your major payors to see if they have differing rules from Medicare.

Trump Administration Proposes to Expand Telehealth Benefits Permanently for Medicare Beneficiaries Beyond the COVID-19 Public Health Emergency and Advances Access to Care in Rural Areas (8/3/20)

https://www.cms.gov/newsroom/press-releases/trump-administration-proposes-expand-telehealth-benefits-permanently-medicare-beneficiaries-beyond

AMA quick guide to telemedicine in practice (7/27/20)

https://www.ama-assn.org/practice-management/digital/ama-quick-guide-telemedicine-practice

Billing for Professional Telehealth Distant Site Services During the Public Health Emergency — Revised (4/3/20)

https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-03-mlnc-se#_Toc36815181

Medicaid Waver for Telehealth (3/23/20)

https://www.cms.gov/newsroom/press-releases/cms-approves-medicaid-section-1135-waivers-11-additional-states-response-covid-19

Medicare Telemedicine Healthcare Provider Fact Sheet (3/17/20)

https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

General Provider Telehealth and Telemedicine Tool Kit

https://www.cms.gov/files/document/general-telemedicine-toolkit.pdf

Additional Information ¹ (March 2020)

CPT and Digital Payment

• CMS made a landmark decision to make separate payment to clinicians for CPT code 99091, retroactively effective January 1, 2018.

99091 – Collection and interpretation of physiologic data (eg, ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time

• CPT code 99091 was created in 2002 to describe the typical patient, practitioner interaction at that time. As remote monitoring technology was still nascent at that time, the code was intended to describe a scenario in which the patient purchased a home monitoring device and submitted the results to their physician via email
• Due to the limited nature of the service, as defined over 15 years ago, the current valuation of code 99091 only includes the work of the physician to review, interpret and report on the patient’s data. It does not include the costs incurred through direct practice expense (e.g. equipment costs, time spent by clinical staff in collecting and scheduling interactions)

CPT and the work of the DMPAG

Remote Physiologic Monitoring (RPM) codes

• The Digital Medicine Payment Advisory Group (DMPAG) saw this gap in appropriate payment and coding and came up with new codes to better describe modern practices who use digital services.
• Three remote physiologic monitoring (RPM) codes were approved by the CPT Panel and will be effective January 1, 2019.

99453 – Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment

99454 – Device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days

99457 – Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month

These codes better represent modern practices because the breadth of services now recognize the work the provider performs to:

• The initial set-up and patient education of the monitoring equipment
• The initial collection, transmission and report/summary services to the clinician(s) managing the patient
• Interpretation of the received data and interaction with patient on a treatment plan by a clinician
• In a big win CMS has finalized coverage for these three services (along with maintaining coverage for 99091) effective January 1, 2019

Interprofessional Internet Consultation Codes

• The CPT Panel also approved two additional codes submitted by the DMPAG to allow the reporting of electronic, non-verbal communication between consulting and treating/requesting physicians
• While codes currently exist to report verbal and written reports, no codes previously existed to report the sending of results without additional verbal communication

99451 – Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a written report to the patient’s treating/requesting physician or other qualified health care professional, 5 minutes or more of medical consultative time

99452 – Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or other qualified health care professional, 30 minutes

• In addition, the Panel also accepted revisions to the current CPT codes, which specify verbal AND written reports are necessary to report the service
• For codes 99446, 99447, 99448, 99449, revisions were made to specify that the use of electronic health records (In addition to telephone and Internet) are acceptable forms of communication
• CMS has approved payment/coverage for all of the services In the Interprofessional Internet consultation family

Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency (3/30/20)

https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

MLN Connects (3/20/20)

https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-03-20-mlnc-se

Blanket Waivers for COVID19 – Emergency Declaration Health Care Providers Fact Sheet (3/30/20)

https://www.cms.gov/files/document/covid19-emergency-declaration-health-care-providers-fact-sheet.pdf

CMS Waiver Summary Fact Sheet (3/17/20)

https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

Coronavirus -SNF-1812f Waiver (3/13/20)

https://www.cms.gov/files/document/coronavirus-snf-1812f-waiver.pdf

CMS 1135 Waiver Information

https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/1135-Waivers

Question: During an emergency, will Medicare allow payment for care provided at a site not considered part of a healthcare facility (which are informally termed “alternative care sites” (ACSs)) for patients who are not critically ill? For example, if local hospitals are almost at capacity during an emergency and the few beds remaining must be reserved for patients needing ventilators and critical care, will Medicare pay for non-critical care provided at an ACS, such as a school gymnasium?

Answer: Even in the absence of an 1135 waiver, a hospital may add a remote location that Page 4 Updated 3/23/20 provides inpatient services, provided that the remote location satisfies the requirements to be provider-based to the hospital’s main campus. The remote location must satisfy all provider based requirements at 42 CFR 413.65, including the location requirements at 42 CFR 413.65(e)(3), in addition to the Hospital Conditions of Participation (CoPs). As soon as it adds an additional location, the hospital would be expected to file an amended Form CMS 855A with its Medicare Administrative Contractor. CMS generally requires a survey of compliance with all CoPs at all new inpatient locations, but also has discretion to waive the onsite survey in this area. An onsite survey is not required for the provider-based designation. Once approved, subsequent surveys of the hospital will include any provider-based locations.   https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

Question: Due to the evacuation of a PPS hospital, the Medicare patients were transferred to a non-Medicare medical facility. How is the claim to be billed?

Answer: The PPS hospital should bill Medicare for all days and charges associated with the patient’s care as if the patient was never transferred from the PPS facility. The PPS facility should make arrangements to reimburse the non-Medicare facility for services/charges associated with the period of time the Medicare patient was in their facility.  https://www.cms.gov/About-CMS/Agency-Information/Emergency/downloads/Consolidated_Medicare_FFS_Emergency_QsAs.pdf

CMS Fact Sheet for Payment for Hospital Alternate Care Sites

https://www.cms.gov/files/document/covid-state-local-government-fact-sheet-hospital-alternate-care-sites.pdf

1. Information provided by the American Medical Association (AMA)

2. "COVID-19 FAQs." Page 3. CMS website. 2020. https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

3. "COVID-19 FAQs." Page 29 CMS website. 2020. https://www.cms.gov/About-CMS/Agency-Information/Emergency/downloads/Consolidated_Medicare_FFS_Emergency_QsAs.pdf