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What Medical Coders Need to Know About Coronavirus—The Ongoing Challenge

The novel coronavirus that is causing the pandemic disease COVID-19 has disrupted every aspect of society and has had a huge impact on all facets of healthcare, including medical coding and billing. Figuring out COVID-19 medical coding so that providers and labs can be paid for related testing and treatment has been confusing, especially since it is rapidly changing.

COVID-19 came on so suddenly there was no time to go through the normal procedure for coming up with a standardized treatment of the disease, much less making carefully evaluated additions to the medical billing codes. And on top of that, the virus spread so fast that the resulting pandemic was declared a national emergency, which meant the government was in a position to make more rule changes for payers and providers.

Initial Steps: Codes for Testing

In February, the first cases were treated in the U.S. and medical billing codes were needed right away. Treatment is often much more extensive than that required for a seasonal flu, so existing coding did not meet the needs of providers.

The Centers for Medicare & Medicaid Services (CMS) bypassed the usual review process to quickly establish two new HCPCS codes that could be used for the newly developed test panels for COVID-19. In March, two more codes were added for specimen collection.

Evaluation and Management (E/M) Codes Added

CMS codes have been added to cover various evaluation and management (E/M) scenarios. These include diagnosis coding with details to indicate presumed cases, known exposure and confirmed cases with related conditions. COVID-19 medical coding is used to help track infection levels and the spread of the disease, so these additional coding details have become important in fighting the pandemic.

Useful Resources for COVID-19 Medical Coding

The American Medical Association (AMA) has published a flowchart laying out billing codes for assessment, swab collection and testing. It specifies which codes should be used for new or established patients, based on where the assessment takes place. The chart includes codes for in-office visits, differentiates codes for E/M telehealth from telephone, and has a separate set of codes for online visits and virtual check-in appointments.

To further clarify COVID-19 medical coding, the AMA published a document called Special coding advice during COVID-19 public health emergency. It illustrates 27 different scenarios with all the appropriate codes and modifiers for each phase and has been updated to add antibody tests. Its thorough coverage of all the possible alternatives should make it especially useful to medical coders during this time when so many things are new.

For example, there are three scenarios in which the patient comes for an E/M in-office visit and needs to be tested for COVID-19. The patient may be tested and have the lab work done in the office, or the sample may be collected and sent out to an external lab. A third alternative is that the patient is sent to a non-affiliated site for sample collection and the sample is sent to a lab from there.

The charts make clear that in the first two alternatives, collecting the swab sample is included in the code for the in-office E/M visit, but the third scenario includes the same codes for the office visit, and an additional code (99211) is given for the sample collection at the external facility, along with a different set of place-of-service codes for that facility (mobile unit, walk-in retail health clinic, urgent care facility or ER hospital).

There are charts similarly differentiating the alternatives for telehealth E/M visits, COVID-19 or non-COVID-19 check-ins, or patient portal visits. There are scenarios for these visits being conducted by a qualified nonphysician as well as regular telehealth visits with a physician, and one giving the right codes for a telehealth visit to the emergency department.

There are even billing details for scenarios that would not have been acceptable prior to the pandemic, such as “Telehealth: initial and continuing intensive care services” and “Telehealth: inpatient neonatal and pediatric critical care.”

Given these unusual situations, it is easy to see why the detailed charts will be useful. The separate charts help to point out the details for each alternative and clarify the modifiers that apply to each aspect of that particular scenario.

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