Wiki COVID Counseling billing E/M 99211

[Cbates18]

We are lab that has an offsite COVID collection site . We started doing the COVID counseling that CMS start 07/30/2020 and want to make sure we are billing correctly.
My question, Can we bill the E/M, collection and test on the same claim

99211, 25 modifier
G2023
U0004, CS modfier

Would this be coded correctly.

Medicare's notice doesn't say if you can bill the E/M and collection code together. We are doing the Counseling that is recommend by CMS and CDC. , and collection for the test.

Any help would be appropriated
Thank you

 

[thomas7331]

Under Medicare guidelines, 99211 can only be billed if all of the 'incident to' requirements are met, which would include direct physician supervision (i.e. physician is at the same site where the service is being performed) of a staff member who is also the physician's employee. If you're a lab provider and the service is being performed off-site, it does not sound like you would be meeting these requirements. Generally speaking, 99211 is reserved for E&M services performed by staff in a free-standing physician's office.

 

[Cbates18]

We (LAB) are working with a Pharmacist group to do the counseling and taking the collections off site.
Michigan does allow for a pharmacists to make the medical decisions if the test is required. Would this then meet the incident to requirements?
Can the 99211 be billed with place of service 81?

 

[Cbates18]

CMS notice from 07/30/2020

Today, the Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention are announcing that payment is available to physicians and health care providers to counsel patients, at the time of coronavirus disease 2019 (COVID-19) testing, about the importance of self-isolation after they are tested and prior to the onset of symptoms.

The transmission of COVID-19 occurs from both symptomatic, pre-symptomatic and asymptomatic individuals emphasizing the importance of education on self-isolation as the spread of the virus can be reduced significantly by having patients isolated earlier, while waiting for test results or symptom onset. The Centers for Disease Control and Prevention (CDC) models show that when individuals who are tested for the virus are separated from others and placed in quarantine, there can be up to an 86 percent reduction in the transmission of the virus compared to a 40 percent decrease in viral transmission if the person isolates after symptoms arise.

Provider counseling to patients, at the time of their COVID-19 testing, will include the discussion of immediate need for isolation, even before results are available, the importance to inform their immediate household that they too should be tested for COVID-19, and the review of signs and symptoms and services available to them to aid in isolating at home. In addition, they will be counseled that if they test positive, to wear a mask at all times and they will be contacted by public health authorities and asked to provide information for contact tracing and to tell their immediate household and recent contacts in case it is appropriate for these individuals to be tested for the virus and to self-isolate as well.

CMS will use existing evaluation and management (E/M) payment codes to reimburse providers who are eligible to bill CMS for counseling services no matter where a test is administered, including doctor’s offices, urgent care clinics, hospitals and community drive-thru or pharmacy testing sites.

Further information and resource links are available in the Counseling Check List PDF here: https://www.cms.gov/files/document/counseling-checklist.pdf

 

[thomas7331]

We (LAB) are working with a Pharmacist group to do the counseling and taking the collections off site.
Michigan does allow for a pharmacists to make the medical decisions if the test is required. Would this then meet the incident to requirements?
Can the 99211 be billed with place of service 81?

No, not under Medicare rules, pharmacists are not providers who are eligible to bill E&M services, nor to supervise employees for purposes of 'incident to' billing. You may with to check with your Medicare carrier, but I suspect that if your provider type is a lab and not a physician practice, you will not be eligible to bill 99211. That code is for physicians to bill when their employees perform services under their supervision and plan of care. I'm not aware that an exception has been granted for this for purposes of the COVID-19 PHE, but given the documentation you've cited that says pharmacy testing sites may do this, your carrier may have made provisions to allow this. My understanding though has been that pharmacists may only bill services to Medicare when they are practicing 'incident to' a physician.