Pathology/Lab Coding Alert

Master ‘G’ codes for independent labs.

With varied sites and personnel for COVID-19 lab-test specimen collection, unraveling when or how to bill for the service can be confusing.

Let our experts walk you through what the code options are, and who can bill each code.

Notice: During the COVID-19 public health emergency (PHE), CMS no longer requires a written lab-test order by a physician or non-physician practitioner (NPP), but will allow any healthcare professional so-authorized under state law to order a COVID-19 diagnostic laboratory test, including concurrent testing for other respiratory viruses such as influenza and respiratory syncytial virus (RSV).

Patient Location Matters for Independent Labs

CMS has provided the following two new HCPCS Level II codes for use by independent labs that send personnel to collect COVID-19 test specimens under specific circumstances:

• G2023 (Specimen collection for severe acute respiratory syndrome coronavirus 2 (sars-cov-2) (coronavirus disease [covid-19]), any specimen source)
• G2024 (Specimen collection for severe acute respiratory syndrome coronavirus 2 (sars-cov-2) (coronavirus disease [covid-19]) from an individual in a snf or by a laboratory on behalf of a hha, any specimen source)

Use G2023 when trained lab personnel travel to collect a COVID-19 test specimen from a homebound or non-hospital inpatient. CMS defines “homebound” as patients for whom a physician has determined that it is medically contraindicated for them to leave home because of a confirmed or suspected COVID-19 diagnosis, or because they have a condition that makes them more susceptible to contracting COVID-19.

Report G2024 when trained lab personnel travel to collect a COVID-19 test specimen from a patient in a skilled nursing facility (SNF) or on behalf of a request from a home health agency (HHA).

Caution: CMS noted in a COVID-19 FAQ that “G2024 is applicable to patients in a non-covered stay in a SNF and not to those residents in Medicare-covered stays (whose bundled lab tests would be covered instead under Part A’s SNF benefit at §1861(h) of the Act).”

Limit: “Don’t use these codes when patients come to a laboratory draw station for lab personnel to take the specimen,” says William Dettwyler, MT AMT, president of Codus Medicus, a laboratory coding consulting firm in Salem, Ore. “There is not currently a way for labs to bill for specimen collection at a draw site in addition to the code for performing the lab test.”

Medicare indicates that the purpose of these codes is to encourage in-place COVID-19 specimen collection for at-risk or potentially infected patients to minimize their exposure outside their residence for safety reasons. The codes are effective for services on or after March 1, for the duration of the COVID-19 PHE.

Capture travel cost: In addition to billing G2023 or G2024, lab personnel can bill for travel expenses using the existing level II HCPCS codes P9603 (Travel allowance one way in connection with medically necessary laboratory specimen collection drawn from home bound or nursing home bound patient; prorated miles actually travelled) for per-mile travel allowance or P9604 (Travel allowance one way in connection with medically necessary laboratory specimen collection drawn from home bound or nursing home bound patient; prorated trip charge) for a flat rate. You don’t need to keep paper documentation, but you must be able to provide electronic travel logs on request.

Payment: CMS will pay a national unadjusted amount of $23.46 for G2023 and $25.46 for G2024. The higher fee for G2024 is because the Social Security Act and CMS regulation require a higher fee for collecting a specimen from an individual in an SNF or on behalf of an HHA.

Know specimen type: Although the codes don’t define the type of specimen collected, CMS indicates nasopharyngeal or oropharyngeal swabs or sputum as the common respiratory specimens used for COVID-19 testing. The code definitions allow the codes to be valid in the future if labs develop tests that use other types of specimens. CMS states in the interim final rule published April 6 in the Federal Register, “If in the future other types of COVID–19 tests are available, such as serological tests or point of care tests, we note that the specimen collection fee would apply if the specimen collection method must be performed by trained laboratory personnel.” However, CMS clarifies that you should not use the codes for specimens that would “require only the services of a messenger pick up service.”

Self-collection caution: Some COVID-19 tests allow patients to take their own specimen and submit it to the lab for analysis. But CMS states, “the specimen collection fee is not available for tests where a patient collects his or her own specimen.”

Industry analysts have also expressed concern about self-collected specimens. “We are concerned that consumers will not carefully follow the directions, which could lead to incorrect sample collection,” said Carmen L. Wiley, PhD, president of the American Association for Clinical Chemistry (AACC) in an April 30 press release. “AACC recommends that the FDA recognize the preanalytical problems with this type of home collection and consider issuing a warning about its use for COVID-19 testing.”

Office Collection is Different

CMS clarified in the interim final rule published May 8 in the Federal Register that physician offices should not bill G2023 or G2024 for COVID-19 test specimen collection.

Rather, practices should bill 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 health care professional. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services) for a visit for COVID-19 assessment and specimen collection for new or established patients. The 2020 national Physician Fee Schedule (PFS) payment amount for 99211 is $23.46, which is comparable to the G2023 payment.

In MLN Matters number MM11805, which summarizes these actions, CMS states that the agency “has finalized new specimen collection fees for COVID-19 testing under the MPFS. Physicians and NPPs must use CPT^® code 99211 to bill for a COVID-19 symptom and exposure assessment and specimen collection provided by clinical staff (such as pharmacists) incident to the physician’s or NPP’s services. This applies to all patients, not just established patients. The direct supervision requirement may be met through virtual presence of the supervising physician or practitioner using interactive audio and video technology. Cost sharing will not apply.”

Expectation: Although CMS did not address the scenario, common coding principles would indicate that you should not bill 99211 for the specimen collection in addition to a higher-level E/M code documented and billed for the same patient on the same date of service. In that case, you might additionally bill 99000 (Handling and/or conveyance of specimen for transfer from the office to a laboratory).

Check Out OPPS Code

To address resource requirements hospitals encounter as they establish broad community COVID-19 testing capabilities, CMS states in the interim final rule published

in the May 8 Federal Register that it is establishing a new code payable under the Outpatient Prospective Payment System (OPPS) for hospital outpatients.

CMS states that HCPCS Level II code C9803 (Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (sars-cov-2) (coronavirus disease [covid-19])) is assigned to ambulatory payment classification (APC) level 8731, which pays a national unadjusted rate of $22.98.

Stand alone: The OPPS will make separate payment to a hospital only when they bill C9803 without another primary covered hospital outpatient service (except a lab-test code).

The code is effective for services on or after March 1. CMS states, “OPPS claims received on or after May 1, 2020, with Coronavirus Specimen Collection HCPCS Codes G2023 and G2024 will be returned to you with edit W7062. Resubmit returned claims as a packaged service to include Code C9803, when appropriate.”

Resources: Much of CMS instruction for billing specimen collection for COVID-19 testing appears in two CMS interim final rules for policy and regulatory revisions in response to the COVID–19 PHE published in the April 6 and May 8 Federal Register:

www.govinfo.gov/content/pkg/FR-2020-04-06/ pdf/2020-06990.pdf, www.govinfo.gov/content/pkg/FR-2020-05-08/ pdf/2020-09608.pdf

You’ll also find a summary of these actions in MLN Matters MM11805 at www.cms.gov/files/document/mm11805.pdf. More relevant information is in the CMS FAQ for COVID-19 at www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf.