Primary Care Coding Alert

Reader Question:

Stay on Top of These New COVID-19 Guidelines, Codes

Question: There have been so many coding changes regarding COVID-19 that we are having trouble keeping up. Have there been any new codes or guideline changes since your last issue?

Illinois Subscriber

Answer: On April 29, the Centers for Medicare & Medicaid Services (CMS) issued a new set of blanket waivers for healthcare providers. Most affected facilities such as hospitals, critical access hospitals (CAHs) and long-term care hospitals (LTCHs), but two telehealth waivers may possibly affect primary care practices:

1) Requirements regarding the types of practitioners who may furnish services “as Medicare telehealth services from the distant site” are currently waived, and for the duration of the PHE, “any healthcare professional that is eligible to bill Medicare for their professional services” may do so.

2) Some telehealth services that require “interactive telecommunications systems” (i.e., that require video) may now be furnished using “audio-only equipment … for audio-only telephone evaluation and management services, and behavioral health counseling and educational services.” Those services are indicated in the column labeled “Can Audio-only Interaction Meet the Requirements?” in the zip file located at www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

Additionally, CMS agreed to increase the payment allowances for the telephone E/M codes (99441-99443) to the same amount allowed for established patient office visits of comparable length. These changes have a retroactive effective date of March 1, 2020 and are effective until the end of the PHE. For the complete updated CMS PHE waivers, go to www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf.  

New COVID-19 Testing Codes Implemented

COVID-19 testing codes have been changed, and some added, since CMS originally created the two temporary codes: U0001 (CDC 2019 Novel Coronavirus (2019-nCoV …) (for CDC laboratories) and U0002 (2019-nCoV Coronavirus…).

First, the American Medical Association (AMA) created code 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) for dates of services on or after March 13, 2020 (Source: www.ama-assn.org/system/files/2020-04/cpt-reporting-covid-19-testing.pdf).

Then, CMS announced two new temporary test codes on April 4: U0003 (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 …) and U0004 (2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC …).

These codes are specifically for tests conducted on “high throughput machines … such as the Roche Cobas 6800 System, Roche Cobas 8800 System, Abbott m2000 System, Hologic Panther Fusion System, GeneXpert Infinity System, and NeuMoDx 288 Molecular.” CMS further stipulates that:

1. “U0003 should identify tests that would otherwise be identified by CPT® code 87635 but [are] being performed with these high throughput technologies.

2. “U0004 should identify tests that would otherwise be identified by U0002 but [are] being performed with these high throughput technologies.

3. “Neither U0003 nor U0004 should be used for tests that detect COVID-19 antibodies.”

(Source: www.cms.gov/files/document/cms-2020-01-r.pdf).

For antibody testing, the AMA has established two new codes: 86328 (Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (eg, reagent strip); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])) and 86769 (Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])). The codes are for single-step (86328) and multiple-step (86769) methods. Code 86328 is “appropriate for a point-of-care platform,” and both codes became effective as of April 10, 2020 (Source: www.ama-assn.org/press-center/press-releases/ama-announces-expedited-updates-cpt-covid-19-antibody-tests).

Modifier alert: For Clinical Laboratory Improvement Amendments (CLIA)-certified labs, Medicare is requiring the QW (CLIA waived test) modifier be appended to U0002 and 87635 “for claims … with dates of service on or after March 20, 2020” (Source: https://www.cms.gov/files/document/r10066OTN.pdf).

As always, while we make every effort to ensure the accuracy of this information at the time of going to press, the situation is changing rapidly. Please remember to consult reputable sources such as CMS and AMA frequently to stay on top of current developments during the emergency.