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CMS Details the Use of CR and DR Codes for Medicare Billing

It’s no secret that COVID-19 billing is challenging. Everything is new and changes are coming up fast. The public health emergency resulting from the COVID-19 pandemic caused the Centers for Medicare & Medicaid Services (CMS) to issue multiple blanket waivers. These are intended to ensure that beneficiaries who are impacted by the emergency do not experience gaps in access to care.

The Introduction of the New Modifiers for COVID-19 Billing

A Medicare Learning Network (MLN) article in the “MLN Matters” series, SE20011, Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19) was published in March to provide information about changes to Medicare billing, and it included special coding to be used when a Medicare claim is filed based on a “formal waiver.”

The article was revised on June 1, 2020 to clarify the use of the CR Modifier and DR Condition Code that were presented in the article. The revision includes a chart detailing what the applicable waivers and flexibilities are, a summary of what they do, and which of the codes is to be used.

This detailed format for clarifying the specifics of COVID-19 billing has been used recently by CMS in other documents and is very helpful, since Medicare billing requires using exactly the right codes or claims will be denied.

The CMS article also indicates that the CR modifier and DR condition code are only required for blanket waivers and flexibilities that are included in the chart, but it will not deny claims because of these notations if they are present in billing for services or items that are related to COVID-19 but not on the list.

Likewise, claims will not be denied because CR/DR is present on items not related to a COVID-19 waiver.

CR Code Use Examples

“CR” is a modifier used for catastrophe/disaster Medicare billing for Part B coverage.

For example, under normal circumstances, the replacement of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) requires a face-to-face, physician’s order and medical necessity documentation. Due to COVID-19, these requirements may be waived, and the CR modifier should be used in the billing code when they are.

Part B drugs and certain durable medical equipment (DME) normally require a proof of delivery and/or beneficiary signature, but in order to minimize the risk of contagious infection, the requirement was waived. This is another instance in which the CR modifier should be used on the claim to indicate the waiver is relevant. In this case, the medical record should also document that a signature could not be obtained because of COVID-19 along with the delivery date.

A much more broad application of the CR modifier is for situations where coverage determination would normally require a face-to face or in-person encounter for evaluations, assessments, etc. During the public health emergency, the requirement is not applicable, so CR is included in medical billing coding where it is not done that way.

Examples of DR Condition Code Usage

The sudden increase in patients due to COVID-19 and the need for isolation of those infected exceeded the capacity of hospitals. Waivers and flexibilities were introduced to give hospitals more internal freedom to move patients between units so they could set up the additional treatment facilities they needed.

For example, under normal circumstances, hospitals with inpatient psychiatric units were required to keep patients in the unit, but waivers allow them to move these patients into acute care as a result of a disaster or emergency. The DR condition code should be used in all billing where this waiver is relevant.

Requirements applying to certain types of facilities have also been waived due to coronavirus. Critical Access Hospitals normally must have their annual average length of stay be not more than 96 hours. This is waived for COVID-19, so the DR code should be used for any relevant billing.

There are many more waivers or flexibilities specified in the chart, and anyone performing Medicare billing should be familiar with them.

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CategoryCOVID-19