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!
Summary of COVID-10 Coding and Billing Rules from CMS
Addition of the QW modifier to Healthcare Common Procedure Coding System (HCPCS) code U0002 and 87635
AMA Covid-19 Resource Center for Physicians
Federal Register Regulatory Updates
AHIMA COVID-19 Resource Page
CDC Announced ICD-10-CM Addenda
CMS MS-DRG Definitions Manual
ICD-10-CM Coding for COVID-19 webinar recording presented by the AHA
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.
Quick-reference flowchart that outlines Current Procedural Terminology (CPT®) reporting for Covid-19 testing
CMS payment policies & regulatory flexibilities during Covid-19 emergency:
Additional resources from the AMA:
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
Medicare Telemedicine Healthcare Provider Fact Sheet
AMA quick guide to telemedicine in practice
General Provider Telehealth and Telemedicine Tool Kit
Medicaid Waver for Telehealth
CPT and Digital Payment
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 and the work of the DMPAG
Remote Physiologic Monitoring (RPM) codes
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:
Interprofessional Internet Consultation Codes
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
ESRD and Elective Surgeries
CMS Releases Additonal Waivers for Hospitals and Ground Ambulance Organizations
COVID-19: Payment for Lab Tests, Safely Reopening Nursing Homes, Lab & Ambulance Claims
Hospital OPPS: New Coronavirus Specimen Collection Code
CMS Reevaluates Accelerated Payment Program and Suspends Advance Payment Program
New Waivers due to provisions of the CARES Act
Important COVID-19 Updates
Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)
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).
Additional Blanket Waivers for patients in LTCHs, RHCs, and FQHCs
CMS Waiver Summary Fact Sheet
CMS 1135 Waiver Information
Blanket Waivers for COVID19 – Emergency Declaration Health Care Providers Fact Sheet
Coronavirus -SNF-1812f Waiver
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