Medicare Compliance & Reimbursement

Question: Can you offer some guidance on the new CPT^® code for reporting additional practice expenses during the COVID-19 public health emergency (PHE) that was released on September 8? What does it include, and how and when can we use it?

Nebraska Subscriber

Answer: The American Medical Association (AMA) introduced 99072 (Additional supplies, materials, and clinical staff time over and above those usually included in an office visit or other nonfacility service(s), when performed during a Public Health Emergency, as defined by law, due to respiratory-transmitted infectious disease) “in response to the significant additional practice expenses related to activities required to safely provide medical services to patients in person during a PHE over and above those usually included in a medical visit or service,” according to the 2020 Special Edition September Update of CPT^® Assistant.

Review the update at www.ama-assn.org/system/files/2020-09/cpt-assistant-guide-coronavirus-september-2020.pdf.

The AMA goes on to say that the code “accounts for additional supplies, materials, and clinical staff time required for patient symptom checks over the phone and upon arrival, donning and removing personal protective equipment (PPE), and increased sanitation measures to prevent the spread of communicable disease.” The code, which can only be used in a “non-facility place of service (POS) setting,” will enable you to document such expenses as:

• Any time beyond the time for the primary service spent by clinical staff (such as registered nurses [RNs], licensed practical nurses [LPNs], or medical technical assistants [MTAs]) in screening the patient for symptoms, both over the phone before the visit and/or at the beginning of the visit, instructing the patient on office PHE protocols, applying and removing PPE, and sanitizing the visit room and any equipment or supplies used after the patient’s departure;
• Three surgical masks; and
• Any supplies used in the sanitizing process, “including additional quantities of hand sanitizer and disinfecting wipes, sprays, and cleansers.”

The CPT^® Assistant Special Edition is vague regarding the code’s documentation requirements, stating only that they “may vary among third-party payers and insurers,” and that those payers “should be contacted to determine their specifications.” The AMA also makes no mention of the code’s relative value units (RVUs) or whether it has a dollar value.

Finally, according to the CPT^® Assistant Special Edition, you can only use the code:

• During a PHE, such as the current COVID-19 PHE, which is “in effect when declared by law by the officially designated relevant public health authority(ies)”; and
• “With an in-person patient encounter for an office visit or other nonfacility service.”