Due to the recent outbreak in COVID-19 paired with increased concern for patients to be seen under quarantine conditions, RT Welter is striving to collect all relevant documentation, coding and billing details to help clinicians assure they receive appropriate reimbursement for unique services they are providing. RT Welter recommends checking with your top payors for coverage benefits, limitations and originating site waivers. Your feedback is greatly appreciated. RT Welter will continue to provide updates as we receive them.  If you have any questions, please contact us at info@rtwelter.com. 

The CPT Editorial Panel approved a new CPT® code at a special, expedited meeting held, via telephone, on Friday, March 13, 2020. A new CPT® code has been created that streamlines novel coronavirus testing offered by hospitals, health systems, and laboratories in the United States. 

NEW CPT 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. 

CPT Assistant has provided a fact sheet for coding guidance for the SARS-CoV-2 (COVID-19) test in relation to the use of the new CPT code. Click here for the fact sheet.

There are two new HCPCS codes for healthcare providers who need to test patients for Coronavirus. Providers using the Centers for Disease Control and Prevention (CDC) 2019 Novel Coronavirus Real-Time RT-PCR Diagnostic Test Panel may bill for that test using the newly created HCPCS code (U0001). A second new HCPCS code (U0002) can be used by laboratories and healthcare facilities to bill Medicare as well as by other health insurers that choose to adopt this new code for such tests. HCPCS code (U0002) generally describes 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19) using any technique, multiple types or subtypes (includes all targets). The Medicare claims processing system will be able to accept these codes on April 1, 2020 for dates of service on or after February 4, 2020. Click here for more information.

Telehealth Evaluation considerations: 

Effective immediately 03/14/2020, United Health Care (UHC) will wave CMS originating site restrictions for Medicare Advantage, Medicaid and commercial members so services can be performed while the patient is in their home, effective until April 30, 2020. United Health care has waived all member cost-sharing, including copays, coinsurance, and deductibles, for COVID-19 diagnostic testing provided at approved locations, in accordance with the Centers for Disease Control and Prevention (CDC) guidelines for all commercial insured, Medicaid and Medicare members. UHC will also reimburse providers for telephone calls to existing patients. 

We’ve found that most payors advise providers billing telemedicine to use the appropriate evaluative and management CPT code (99201 – 05, 99211-15) along with a GT modifier.
Although, MM10152 from January 1, 2018 eliminates the requirement of the use of GT modifier on professional claims. Click here for more information.

Private payors may prefer that you use the telemedicine specific code 99444. It varies based on the payer and the state guidelines.

Many of the MACs have yet to loosen the reigns on the originating site requirement with the use of “02” Place of Service with an office visit code. There are many other payors, including Medicare Advantage plans that have waived the originating site requirement.  

CMS is recommending the use of G2012 for telehealth services in a recent press release:

Code G2012 has specific guidelines and documentation requirements to keep in mind when considering the appropriate use of this code:  

G2012 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion).

Reimbursement according to the recent MFS is $14.89.

  • The service is communication technology-based
  • The provider can be a physician or other qualified health care professional who reports E/M services
  • Interaction must be between the patient and billing practitioner, not clinical staff.
  • The communication can’t be related to an E/M service from within the previous seven days.
  • The communication can’t lead to an E/M service within 24 hours (or soonest available): The language in the code descriptor states, “nor leading to an E/M service or procedure within the next 24 hours.” Consequently, Medicare will be watching for an uptick in appointments occurring 25 hours or so after the call. Do not game the system to get around the 24-hour limitation.
  • The code represents five to 10 minutes of medical discussion.
  • The medical record must document verbal consent from the patient for each billed service. Cost-sharing applies, and the beneficiary co-payment isn’t waived.
  • The service is available only to established patients, defined as patients who have “received professional services from the physician or qualified health care professional or another physician or qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice, within the past 3 years.”

Health First of Colorado states, “Place of Service 02 should be used to report services delivered via telecommunication, where the member may be in their home and the provider may be at their office.” 

Non-F2F evaluation & management telephone services 99441-99443 may also be a consideration. This category of codes have yet to be recognized as CMS for reimbursement. Many other payors also do not cover these services. RT Welter recommends verifying coverage, limitations and reimbursement with your top payers for these services. 

Modifier Considerations: 

Use of GT modifier on Medicare claims was eliminated in 2018. According to CMS, the place of service code 02 is sufficient. See the instructions below for appropriate consideration of CR modifier. 

Change Request (MLN) MM10152 from January 1, 2018 eliminates the requirement to use the GT modifier (via interactive audio and video telecommunications systems) on professional claims for telehealth services. Use of the telehealth Place of Service (POS) Code 02 certifies that the service meets the telehealth requirements. Click here to read the request.

Effective August 31, 2009, the use of the CR modifier will be mandatory for applicable HCPCS codes on any claim for which Medicare Part B payment is conditioned directly or indirectly on the presence of a “formal waiver.”

The CR Modifier: Both the short and long descriptors of the CR modifier are “catastrophe/disaster-related.” The CR modifier is used in relation to Part B items and services for both institutional and non-institutional billing. Non-institutional billing, i.e., claims submitted by “physicians and other suppliers”, are submitted either on a professional paper claim form CMS-1500 or in the electronic format ANSI ASC X12 837P or – for pharmacies – in the NCPDP format. In previous emergencies, use of the CR modifier was entirely discretionary with the billing provider or supplier. It no longer may be used at the provider or supplier’s discretion. Effective August 31, 2009, the use of the CR modifier will be mandatory for applicable HCPCS codes on any claim for which Medicare Part B payment is conditioned directly or indirectly on the presence of a “formal waiver.”

See the MLN in its entirety for appropriate consideration of the CR Modifier here.

Diagnosis (ICD10COM) Coding for COVID-19: Interim coding advice for COVID-19 has been provided by the CDC here. Clinicians are reminded to follow HIPAA mandated diagnosis coding guidance by reporting signs or symptoms until a definitive diagnosis has been made.