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! 

Coding Information

Summary of COVID-10 Coding and Billing Rules from CMS

https://www.cms.gov/files/document/r10160otn.pdf

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

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

AMA Covid-19 Resource Center for Physicians

https://www.ama-assn.org/delivering-care/public-health/covid-19-2019-novel-coronavirus-resource-center-physicians

Federal Register Regulatory Updates

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

New Codes

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

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

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

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

https://www.cms.gov/medicare/coding/hcpcsreleasecodesets/hcpcs-quarterly-update

https://journal.ahima.org/ahima-and-aha-faq-on-icd-10-cm-coding-for-covid-19/

https://journal.ahima.org/new-cpt-code-announced-to-report-novel-coronavirus-test

AHIMA COVID-19 Resource Page

http://www.ahima.org/topics/covid-19

CDC Announced ICD-10-CM Addenda

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

CMS MS-DRG Definitions Manual

https://www.cms.gov/icd10m/version38-fullcode-cms/fullcode_cms/P0001.html

ICD-10-CM Coding for COVID-19 webinar recording presented by the AHA

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

AMA Coding Guidance

This resources provides guidance from the AMA during the COVID-19 public health emergency, and is designed to help healthcare professionals apply best coding practices. The scenarios include telehealth services for all patients.

https://www.ama-assn.org/system/files/2020-03/covid-19-coding-advice.pdf

Quick-reference flowchart that outlines Current Procedural Terminology (CPT®) reporting for Covid-19 testing

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

CMS payment policies & regulatory flexibilities during Covid-19 emergency:

https://www.ama-assn.org/delivering-care/public-health/cms-payment-policies-regulatory-flexibilities-during-covid-19

Additional resources from the AMA:

https://www.ama-assn.org/delivering-care/public-health/covid-19-2019-novel-coronavirus-resource-center-physicians


Telehealth

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

Billing for Professional Telehealth Distant Site Services During the Public Health Emergency — Revised

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

Medicare Telemedicine Healthcare Provider Fact Sheet

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

AMA quick guide to telemedicine in practice

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

General Provider Telehealth and Telemedicine Tool Kit

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

Medicaid Waver for Telehealth

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

Additional Information1:

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

HIPAA Rules

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


ESRD and Elective Surgeries

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


MLN Matters

CMS Releases Additonal Waivers for Hospitals and Ground Ambulance Organizations

https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-05-21-mlnc#_Toc40870418

COVID-19: Payment for Lab Tests, Safely Reopening Nursing Homes, Lab & Ambulance Claims

https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-05-19-mlnc-se

Hospital OPPS: New Coronavirus Specimen Collection Code

https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-05-07-mlnc#_Toc39656772

CMS Reevaluates Accelerated Payment Program and Suspends Advance Payment Program

https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-27-mlnc-se

New Waivers due to provisions of the CARES Act

https://www.cms.gov/files/document/se20015.pdf

Important COVID-19 Updates

https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-09-mlnc

Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)

https://www.cms.gov/files/document/se20011.pdf\

MLN Matters – Supplier Education on Use of  Upgrades for Multi-Function Ventilators

Billing for Multi-Function Ventilators (HCPCS Code E0467) under the COVID-19 Public Health Emergency and Otherwise

CMS recognizes that in these important times, in particular, beneficiaries, health care clinicians, suppliers, and manufacturers are looking for the broadest possible access to ventilators for their care needs.  We are taking a number of steps to increase access to and remind suppliers about certain options available to them and beneficiaries regarding multi-function ventilators.

Effective immediately, CMS is suspending claims editing for multi-function ventilators when there are claims for separate devices in history that have not met their reasonable useful lifetime.

For more information on multi-function ventilators, see MLN Matters Special Edition Article SE20012 (PDF).


Waivers

Additional Blanket Waivers for patients in LTCHs, RHCs, and FQHCs

https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf

CMS Waiver Summary Fact Sheet

https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf

CMS 1135 Waiver Information

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

Blanket Waivers for COVID19 – Emergency Declaration Health Care Providers Fact Sheet

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

Coronavirus -SNF-1812f Waiver

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


Alternate Care Facility FAQs2, 3

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

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