ICD 10 Coding Alert

Even as mandates end, new treatment codes may require your attention.

Coding a COVID-19 infection has always been tricky, but now that there are new treatments and patients who may be experiencing their second or third COVID-19 infection, coders may feel a little confused about exactly when and what to record.

Take a — or another — deep dive into the intricacies of coding an encounter where your clinician sees a patient with COVID-19.

Don’t Worry Much About Service Coding

Currently, most of the Food & Drug Administration (FDA)-approved and Emergency Use Authorization (EUA) treatments for COVID-19 are only available in hospital and certain home-care settings. Primary care physicians (PCPs) and other clinicians will continue to counsel and recommend treatments and then see patients for follow-up. “So, from a service coding perspective, the issues would be those common to coding E/M [evaluation and management] services,” says Kent Moore, senior strategist for physician payment at the American Academy of Family Physicians.

Here are a few things to consider when coding these encounters.

Rely on Knowledge of E/M Guidelines for Comorbidities

As with any office or outpatient E/M, you’ll establish the level of service based on level of medical decision making (MDM) or total time spent on the date of the encounter. The trick is to not get distracted by outside knowledge of complications and comorbidities. Stick to what’s documented.

That’s not to say comorbidities won’t ever move a COVID-19 E/M encounter from low to moderate (or even to a high) level of MDM. That will depend on whether your provider establishes a connection between a patient’s COVID infection and the patient’s known comorbidities. Remember that “comorbidities/underlying diseases, in and of themselves, are not considered in selecting a level of E/M services unless they are addressed, and their presence increases the amount and/ or complexity of data to be reviewed and analyzed,” per the CPT^® guidelines for Office or Other Outpatient E/M Services.

For example, if a patient has a history of COPD and asthma, coding J44.- (Other chronic obstructive pulmonary disease) or J45.- (Asthma) for the current encounter is not appropriate unless the clinician’s notes for that visit clearly indicate the conditions’ relevance to the projected treatment course. Further, as noted above, don’t count those problems toward the level of MDM unless the clinician “addressed” them. Per CPT^® guidelines, “A problem is addressed or managed when it is evaluated or treated at the encounter by the physician or other qualified health care professional reporting the service.” If a clinician’s notes are unclear, request clarification.

Distinguish Between U07.1 and U09.9

When a patient has a current, confirmed COVID diagnosis, code the active infection as the primary condition using U07.1 (COVID-19). If the clinician has noted manifestations, code those as secondary issues. For example, you’d use J22 (Unspecified acute lower respiratory infection) in addition to U07.1 if the records show the patient contracted a lower respiratory infection as a result of COVID.

If at a follow-up visit, the patient no longer has an active infection and therefore tests negative, follow the instructions provided by ICD-10 Official Guidelines, Section I.C.1.g. They tell you to assign code Z09 (Encounter for follow-up examination after completed treatment for conditions other than malignant neoplasm) as well as Z86.16 (Personal history of COVID-19) once the person no longer tests positive for COVID-19 and no longer suffers from symptoms at the time of that encounter.

If the patient exhibits residual symptoms at the follow-up, you’ll need to use the codes for the symptoms themselves, such as R05.1 (Acute cough), R06.02 (Shortness of breath), or R50.9 (Fever, unspecified), followed by U09.9 (Post COVID-19 condition, unspecified).

Know When to Use U07.1 and U09.9 Together

In certain situations, you may have to use both U07.1 and U09.9 at the same time. Even though U09.9 “is not to be used in cases that are still presenting with active COVID-19, an exception is made in cases of re-infection with COVID-19 occurring with a condition related to the prior COVID-19 infection. Per ICD-10, code first the specific condition related to the COVID-19 if known,” Moore explains.

In cases like this, you will first code the issues associated with the inactive infection, then code U09.9. Then code the active infection using U07.1, followed by its manifestations. Some common ones are:

• J96.1- (Chronic respiratory failure)
• M35.81 (Multisystem inflammatory syndrome)
• J84.10 (Pulmonary fibrosis, unspecified)
• I26.- (Pulmonary embolism)
• J12.82 (Pneumonia due to coronavirus disease 2019)
• J20.8 (Acute bronchitis due to other specified organisms)

What’s Coming Down the Pike?

While many clinicians may be feeling generally positive about the existence of new COVID-19 treatments, “it’s difficult to address specific questions about any individual treatment… and with limited supplies, it’s not always possible to obtain the medication of choice for the patient,” notes Sterling Ransone Jr., MD, president of the American Academy of Family Physicians.

The information is constantly changing, which means it’s possible we’ll see a shift to PCP-administered treatments as research evolves. If we were to see a location change soon, these are some codes to look out for:

• Q0222 (Injection, bebtelovimab, 175 mg)
• M0222 (Intravenous injection, bebtelovimab, includes injection and post administration monitoring)
• J0248 (Injection, remdesivir, 1 mg)

Please note: Remember, these HCPCS Level II codes do not represent current treatments available in a primary care setting, so keep up to date as new treatment modalities emerge. Currently, remdesivir is the only FDA-approved treatment in this list, though bebtelovimab does have EUA. Also, these codes are subject to change, as the temporary Q-code assignment for the 175 mg bebtelovimab injection especially indicates.