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    Christian Green
    Christian Green, MA
    Veronica Bradley
    Veronica Bradley, CPC, CPMA

    Editor's note: The information supplied here was published March 27, 2020. For the latest resources, visit the COVID-19 Recovery Center.

    The Medical Group Management Association’s most recent MGMA Stat poll asked healthcare leaders: “Will you use the new ICD-10-CM and lab testing codes for COVID-19?” The majority (64%) answered “yes,” while 36% responded “no.”

    The poll was conducted March 25, 2020, with 530 applicable responses.

    On March 13, the Current Procedural Terminology (CPT®) Editorial Panel of the American Medical Association (AMA) approved CPT® code 87635 to aid in streamlining data-driven allocation and resource planning in the fight against novel coronavirus (SARS-CoV-2). The new Category I CPT® code and long descriptor is:

    • 87635 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique

    The code is now the industry standard for reporting tests for the novel coronavirus. In addition, the AMA’s CPT Assistant has provided a fact sheet, which includes information on the microbiology of SARS-CoV-2, a clinical example, the description of the procedure and answers to frequently asked questions.
    Coding guidance for respiratory issues is available via the National Center for Healthcare Statistics with its International Classification of Diseases, Tenth Revision, Clinical Modification (ICD-10-CM), based on the World Health Organization’s (WHO) International Classification of Diseases. 

    ICD-10-CM coding guidance

    The following respiratory conditions potentially tied to COVID-19 should be assigned as follows:

    • Acute bronchitis
      • Due to COVID-19: J20.8
      • Due to other specified organism: B97.29
      • Not acute, due to COVID-19: J40
      • Not acute or chronic: B97.29
    • Acute respiratory distress syndrome (ARDS)
      • Due to COVID-19: J80
      • Due to acute respiratory distress syndrome: B97.29
    • Exposure to COVID-19
      • Possible exposure, but COVID-19 ruled out: Z03.818
      • Exposure to someone with COVID-19: Z20.828 (code not necessary if patient has disease)
    • Lower respiratory infection
      • Associated with lower respiratory infection (not otherwise specified) or acute respiratory infection (NOS): J22
      • Unspecified acute lower respiratory infection: B97.29
      • COVID-19 associated with respiratory infection (NOS): J98.8
      • Other specified respiratory disorders: B97.29
    • Pneumonia
      • Confirmed due to COVID-19: J12.89
      • Other viral pneumonia and other coronavirus as cause of diseases classified elsewhere: B97.29
    • Signs and symptoms
      • Cough: R05
      • Fever unspecified: R50.9
      • Shortness of breath: R06.02

    In addition, you should not report “suspected” cases of COVID-19 with B97.29 and B34.2, coronavirus infection, unspecified.

    87635 coding guidance

    Healthcare organizations should manually load CPT® code 87635 into their EHRs, practice management systems or billing systems, since the code is new. Although the code is not included in CPT Professional 2020, it will be slotted for the Microbiology subsection of the Pathology and Laboratory section of the 2021 code set.
    The AMA and the Centers for Medicare & Medicaid Services (CMS) have provided guidelines regarding when to use 87635 versus U-codes (documentation insufficient to determine if the condition was present at the time of inpatient admission) for testing for COVID-19.
    Similar to influenza, there isn’t a code for swabbing patients for COVID-19. However, if your office plans to send the specimen to an outside lab, the specimen collection should be coded as 99000.

    Correspondingly, CMS has developed two new lab testing codes for COVID-19:

    • U0001 will be reported for coronavirus testing using the Centers for Disease Control and Prevention (CDC) 2019 Novel Coronavirus Real Time RT-PCR Diagnostic Test Panel.
    • U0002 will be reported for validated non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19).

    If your office is not testing for COVID-19 or incurring the cost to do so, you will not report these codes.
    As the CDC noted last week, the effective date for diagnosis code U07.1 has been moved up from Oct. 1 to April 1. As a result, per CMS, the Medicare claims processing system can accept this code for payment for service on or after Feb. 4, 2020.
    Some of the nation’s largest payers have reported that they will provide lab tests with no out-of-pocket expense and many are waiving copayments for all diagnostic testing tied to COVID-19 and for synchronous telehealth visits.

    Lifting of telehealth restrictions by CMS

    Following the March 6 signing of the Coronavirus Preparedness and Response Supplemental Appropriations Act of 2020 (H.R. 6074), Department of Health & Human Services (HHS) Secretary Alex Azar was given authority to waive certain Medicare telehealth restrictions, effective for the duration of the COVID-19 public health emergency, including:

    • Geographic restrictions, meaning patients can receive telehealth services in non-rural areas
    • Originating site restrictions, meaning patients can receive telehealth services in their home
    • Allow use of telephones that have audio and video capabilities.

     Additionally, the guidance issued with the waivers implemented by CMS noted further changes:

    • Allow reimbursement for any telehealth covered code, even if unrelated to COVID-19 diagnosis, screening or treatment
    • No enforcement of the established relationship requirement that a patient see a provider within the last three years.

    In addition, effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against healthcare providers who serve patients in good faith through everyday communications technologies, such as FaceTime or Skype.
    For more on waived Medicare telehealth restrictions, access MGMA’s COVID-19 resource. And for the most-recent updates on the Association’s response to coronavirus and its associated illness, access the MGMA Federal Assistance and Advocacy Center.

    Would you like to join our polling panel to voice your opinion on important practice management topics? MGMA Stat is a national poll that addresses practice management issues, the impact of new legislation and related topics. Participation is open to all healthcare leaders. Results of other polls and information on how to participate in MGMA Stat are available at:

    Additional resources:

    Christian Green
    Veronica Bradley

    Written By

    Veronica Bradley, CPC, CPMA

    Veronica Bradley, CPC, CPMA, has more than 20 years’ experience in medical coding and auditing in various specialties. She is also well-versed hierarchical condition category and risk adjustment coding. Other areas of expertise include E/M, procedural coding, Medicare reimbursement and other critical factors in coding and auditing. Veronica has worked in private practice, group practices, academic school of medicine and hospitals. Veronica received a bachelor’s degree in health information management and a minor in healthcare administration from Regis University in Denver.

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