Medicare Compliance & Reimbursement

Question: Our practice needs COVID-19 testing advice. If one of our clinicians does a telehealth visit with a patient, then instructs the patient to come to the office for a COVID-19 swab, does that qualify for 99211 or just the prep and handling code for a send-out specimen?

Connecticut Subscriber

Answer: The American Medical Association (AMA) offers guidance by way of a flow chart at www.ama-assn.org/system/files/2020-05/cpt-reporting-covid-19-testing.pdf. According to the AMA, you should report this encounter using the following CPT^® codes:

First, report the telehealth visit, adding modifier 95 (Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System) and the place of service (POS) for the location where the visit would have occurred otherwise (e.g. POS 11 for “Office”) for Medicare claims. Note that you can do this for the duration of the public health emergency (PHE); pre-pandemic, the Centers for Medicare & Medicaid Services (CMS) required you to report a telehealth visit with POS 2 (Telehealth).

Watch out: This could change back once the PHE is lifted.

Next, report 99211 (Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified healthcare professional. …) for the swab collection, appending modifier 25 (Significant, separately identifiable evaluation and management service by the same physician or other qualified healthcare professional on the same day of the procedure or other service) if the collection occurs on the same day as the telehealth visit.

Finally, report 99000 (Handling and/or conveyance of specimen for transfer from the office to a laboratory) if you incur any costs in preparing or delivering the specimen to the lab.

Heads Up: Medicare doesn’t separately pay for 99000, considering payment for it to be bundled in with the payment made for other services. Also note that commercial payers may not follow these reporting procedures.