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

Blog updated on May 6, 2020 and July 31, 2020

As of July 25th, Health and Human Services (HHS) officially extended the PHE declaration for an additional 90 Days through October 25, 2020. This means that accelerated payments, the 20% add-on for Medicare COVID-19 patients, and the telehealth provisions that have helped many care providers survive the pandemic will still be in place for the foreseeable future.

In addition, Centers for Medicare and Medicaid Services (CMS) Administrator, Seema Verma, said recently that CMS is actively assessing telehealth’s expanded role, including reimbursement rates and the possibility of making the changes permanent.

COVID-19 continues to impact on a global scale with over 3.7 million 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 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 (HDHP) 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

UPDATE: On September 8, 2020, the AMA added a new code for COVID-19 billing. CPT code 99072 is intended to recognize additional supplies and clinical staff time being used to contain and stop the coronavirus. This code should only be used once per in-office visit (not for each procedure performed) and only during a public health emergency. It can be used in addition to code 99070 which denotes regular supplies and materials.

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, especially for non-COVID-19 related care, testing, and treatment.

One major concern for providers and hospitals remains scaling up for the 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 revenue cycle management 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.  For guidance on telehealth coding, view our resources here.

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 codes:
  • 87635 – Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]).
  • 86328 – Immunoassay for infectious agent antibody(ies), qualitative or semiqualitative, severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), single step method.
  • 86413 – Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) antibody, quantitative.
  • 86769 – Immunoassay for infectious agent antibody(ies), qualitative or semiqualitative, severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), multiple step method.
  • U0001 – 2019 Novel Coronavirus real time RT-PCR diagnostic test panel at a CDC lab.
  • U0002 – 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19) using any technique, multiple types of subtypes at a non-CDC lab.
  • U0003 – Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID19]), amplified probe technique, making use of high throughput technologies as described by CMS-2020-01-R.
  • U0004 – 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, making use of high throughput technologies as described by CMS-2020-01-R.
  • G2023 – Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Cororavirus disease [COVID-19]), any specimen source.
  • G2024 – Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Cororavirus disease [COVID-19]), from an individual in an SNF or a laboratory on behalf of an HHA, any specimen source.
  • P9603 – Travel allowance, one way in connection with medically necessary laboratory specimen collection drawn from homebound or nursing homebound patient; prorated miles actually traveled.
  • P9604 – Travel allowance, one way in connection with medically necessary laboratory specimen collection drawn from homebound or nursing homebound patient; prorated trip charge.
• According to the World Health Organization, the ICD-10-CM has been updated to reflect the following:
  • For Testing:
    • ACode U07.1 has been assigned to 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.
  • 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, including asymptomatic individuals.
  • 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 Confirmed Cases:
    • B97.29 (Other coronavirus as the cause of diseases classified elsewhere). If the provider documents “suspected,” “possible” or “probable” COVID-19, do not assign code B97.29. Assign a code(s) explaining the reason for encounter (such as fever, or Z20.828).  
    • B34.2 (Coronavirus infection, unspecified).  NOTE:  This code is not generally appropriate for COVID-19 because confirmed cases have universally been respiratory in nature, so the site would not be unspecified.
  • For a pneumonia case confirmed as due to the 2019 novel coronavirus (COVID-19), assign code:
    • J12.89 (Other viral pneumonia)
  • 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)

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.