28 COVID-19 Billing & Coding FAQs (and Answers)

Effective for dates of service on or after April 1, 2020, pneumonia that has been confirmed as due to the 2019 novel coronavirus (COVID-19) should be coded using two diagnosis codes: U07.1, COVID-19, as the primary or first-listed diagnosis code, and J12.89, Other viral pneumonia, as an additional diagnosis code. For dates of service prior to April 1, 2020, a patient with pneumonia confirmed to be due to COVID-19 would be assigned diagnosis codes J12.89 as the primary or first-listed diagnosis code and B97.29, Other coronavirus as the cause of diseases classified elsewhere, according to the supplemental ICD-10-CM Official Coding Guidelines for coding encounters related to COVID-19 Coronavirus outbreak published by the Centers for Disease Control (CDC) on February 20, 2020.¹ Additional guidance was developed jointly by the American Hospital Association (AHA) and the American Health Information Management Association (AHIMA) and published on March 20, 2020 with an update on March 24, 2020.²

¹ICD-10-CM Official Coding Guidelines – Supplement Coding encounters related to COVID-19 Coronavirus Outbreak

²AHIMA – Frequently Asked Questions Regarding ICD-10-CM Coding for COVID-19

Patients presenting with signs and symptoms of COVID-19 where a definitive diagnosis has not been established should be assigned codes which reflect their signs and symptoms. If the physician documents suspected, possible, probable, or presumed COVID-19 infection, diagnosis code U07.1, COVID-19, should not be assigned. If the patient has a known or suspected exposure to COVID-19, you should add diagnosis code Z20.828, Contact with and (suspected) exposure to other viral communicable diseases.

Assign diagnosis codes J20.8, Acute bronchitis due to other specified organisms, and an appropriate secondary diagnosis code to identify the specific causative organism such as B97.21, SARS-associated coronavirus as the cause of diseases classified elsewhere, or B97.29, Other coronavirus as the cause of diseases classified elsewhere, for patients presenting with acute bronchitis due to a strain of coronavirus other than COVID-19.

The collection of the specimen by clinical staff during the course of an Evaluation and Management (E/M) visit is included in the E/M visit according to “Special coding advice during COVID-19 public health emergency” published by the American Medical Association (AMA).¹ A low-level E/M code, such as 99211, Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional, may be assigned when a throat swab is obtained by clinical staff for testing when no separate E/M service is performed.

¹AMA – Special coding advice during COVID-19 public health emergency

HCPCS codes U0001, CDC 2019 novel Coronavirus (2019-nCoV) real-time RT-PCR diagnostic panel, and U0002, 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, were created by the Centers for Medicare & Medicaid Services (CMS) to report COVID-19 testing. Both codes are effective for use on or after February 4, 2020, although CMS has instructed the Medicare Administrative Contractors (MACs) to hold claims containing these codes for processing until April 1, 2020. The first test kits were sent to state and local public-health labs by the CDC on February 7, 2020, so all testing for COVID-19 should be covered using one of these codes.

A code for possible or suspected exposure to the virus would only be necessary if the suspected exposure meets criteria for reporting of additional diagnoses, meaning that the exposure affected patient care in terms of requiring clinical evaluation, therapeutic treatment, diagnostic procedure, extended length of stay, or increased nursing care or monitoring. If the suspected exposure does meet criteria for reporting and the patient is without signs or symptoms of the disease, diagnosis code Z20.828, Contact with and (suspected) exposure to other viral communicable diseases, may be appropriate for reporting. According to the ICD-10-CM Official Guidelines for Coding and Reporting I.C.21.c.1, category Z20 indicates contact with, and suspected exposure to, communicable diseases and may be used for patients without signs or symptoms of a disease but who are suspected to have been exposed to it either by close personal contact with an infected individual or by virtue of being in an area where the disease is epidemic. If the patient has signs and symptoms of COVID-19, it would be appropriate to code the signs and symptoms that qualify for reporting of additional diagnoses.

HCPCS code U0001, CDC 2019 novel Coronavirus (2019-nCoV) real-time RT-PCR diagnostic panel, is used to report tests that are performed using the CDC test kit, which is provided to laboratories at no cost. The reimbursement associated with HCPCS code U0001 covers the costs associated with performing the test.

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, is specific to the amplified probe technique for detection of the virus by DNA or RNA while HCPCS code U0002, 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, includes all techniques. The COVID-19 FAQ document published by CMS directs laboratories to assign 87635 when they use the methodology described by the code and to use U0002 when they use a method not described by code 87635.¹

¹CMS COVID-19 FAQs

ICD-10-CM code U07.1, COVID-19, is not retroactive and therefore cannot be used prior to April 1, 2020. Prior to April 1, a diagnosis code for the underlying respiratory infection should be assigned along with code B97.29, Other coronavirus as the cause of diseases classified elsewhere, as a secondary diagnosis code to report confirmed COVID-19 infections.

Presumptive positive COVID-19 test results should be coded as confirmed, according to “Frequently Asked Questions Regarding ICD-10-CM Coding for COVID-19”, which was developed and published jointly by the AHA and AHIMA. Their guidance indicates that a presumptive positive result means that an individual has tested positive for the virus at a local or state level, but the test result has not yet been confirmed by the CDC.

In the scenario outlined above, you would assign a code for the specific type of bronchitis that is documented in the record. No further codes are necessary, although you may assign diagnosis code Z20.9, Contact with and (suspected) exposure to unspecified communicable disease.

CMS has not formally released test pricing for 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. However, several commercial payors, including UHC, Aetna, and Blue Cross, have announced that reimbursement for 87635 will be equivalent to the reimbursement rate for HCPCS code U0002, 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, which is currently $51.31 or $51.33 depending upon region.

According to special coding guidance published by the AMA, the collection of the specimen by clinical staff may be reported using a low-level E/M visit such as 99211, Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional, or G0463, Hospital outpatient clinic visit for assessment and management of a patient.

CMS published ICD-10 MS-DRGs Version 37.1 R1, effective April 1, 2020, on March 23, 2020. Although the software has not been released as of March 26, 2020, the assignment of new ICD-10-CM diagnosis code U07.1, COVID-19, is as follows:

MS DRG Grouping Information for COVID 19

Note that if diagnosis code U07.1 is reported as a principal diagnosis, it will only exclude itself from acting as an MCC under the CC Exclusions List.

According to CPT® Assistant Special Edition 2020/Volume 30, CPT® code 87632, Infectious agent detection by nucleic acid (DNA or RNA); respiratory virus (eg, adenovirus, influenza virus, coronavirus, metapneumovirus, parainfluenza virus, respiratory syncytial virus, rhinovirus), includes multiplex reverse transcription, when performed, and multiplex amplified probe technique, multiple types or subtypes, 6-11 targets, is used for nucleic acid assays that detect multiple respiratory viruses in a multiplex reaction, while 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, is for detection of SARS-CoV-2 (COVID-19) and any pan-coronavirus types or subtypes.

The existing guidelines for coding viral sepsis have not changed. Viral sepsis was specifically addressed by the AHA in the 2016Q3 Coding Clinic. This guidance states, in part, that ICD-10-CM code A41.89, Other specified sepsis, should be assigned for a diagnosis of viral sepsis along with an additional diagnosis code to identify the specific type of viral infection. In the scenario outlined above, ICD-10-CM code U07.1, COVID-19, would be assigned.

If the physician documents viral pneumonia without any further clarification, ICD-10-CM code J12.9, Viral pneumonia, unspecified, should be assigned. It may be necessary to query the physician for further information as to the underlying cause of the pneumonia as there are many different viruses that may cause pneumonia.

The first test kits that specifically tested for the COVID-19 virus were sent to state and local public-health labs by the CDC on February 7, 2020, so all testing for COVID-19 should be covered using either HCPCS codes U0001, CDC 2019 novel Coronavirus (2019-nCoV) real-time RT-PCR diagnostic panel, or HCPCS code U0002, 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC. For dates of service on or after March 13, 2020, 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, is available for use as well.

Condition code DR, Disaster Related, would be used at the claim level when all of the services/items are related to the COVID-19 pandemic. Modifier CR, Catastrophe/Disaster Related, would be appended to the line item services that are related to the COVID-19 pandemic. The challenge may be having a mechanism in place to identify the claims. Using the new diagnosis codes would be one indication; however, the CMS documentation states the services could be either directly or indirectly related.¹

For patients coming to the facility, generally through the Emergency Department (ED) or other type of staging area, those may have the signs and symptoms of fever, cough, shortness of breath, or other manifestations of the virus would be somewhat easier to identify. A patient presenting with appendicitis as a chief complaint would more than likely not have a disaster-related claim.

¹Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)

Although this scenario is not specifically addressed in the supplemental ICD-10-CM Official Coding Guidelines related to COVID-19 coronavirus outbreak, Vitalware would not recommend assigning a code for exposure unless there is exposure to a known COVID-19 patient. The intent of the supplemental coding guidelines is to allow for improved tracking of confirmed COVID-19 cases. Infections that are suspected or likely to be caused by the COVID-19 virus are not coded as confirmed cases and therefore unconfirmed exposure would also not be coded.

Severe respiratory failure is a defining component of Acute Respiratory Distress Syndrome (ARDS), a separate code for respiratory failure is not assigned for an ARDS diagnosis. An exception would be when respiratory failure was already present due to another cause before ARDS occurred. The Excludes1 notes associated with category J96, Respiratory failure, not elsewhere classified, contain ARDS (J80) as an exclusion.

Yes, codes for both pneumonias would be assigned in the scenario described above since both conditions would meet criteria outlined in Section III (Reporting Additional Diagnoses) of the ICD-10-CM Official Guidelines for Coding and Reporting. Per these guidelines, additional diagnoses should be assigned for “all conditions that coexist at the time of admission, that develop subsequently, or that affect the treatment received and/or length of stay.”

If your facility is not performing the test, it would not be appropriate to report a code for testing. HCPCS code U0001, CDC 2019 novel Coronavirus (2019-nCoV) real-time RT-PCR diagnostic panel, was created to allow healthcare providers who test patients for coronavirus using the CDC RT-PCR Diagnostic Test Panel to bill for this service. However, the specimen collection may be separately reportable if done without an associated E/M visit. For patients who present only for specimen collection for purposes of confirming or ruling out a COVID-19 infection, a low-level E/M visit code such as 99211, Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional, or G0463, Hospital outpatient clinic visit for assessment and management of a patient, may be reported. Specimen collection that is performed by staff of an independent laboratory may assign HCPCS code G2023, Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source, or HCPCS code G2024, Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), from an individual in a SNF or by a laboratory on behalf of a HHA, any specimen source.

The hospital should not bill a facility fee for telehealth visits unless the patient is in the hospital. If the patient is an outpatient or inpatient at a hospital, HCPCS code Q3014, Telehealth originating site facility fee, may be billed for telehealth services. The new waivers related to telehealth services do not change the list of qualified providers who are permitted to furnish telehealth services. Qualified providers include physicians and certain non-physician practitioners such as nurse practitioners, physician assistants, and certified nurse midwives. Additionally, certified nurse anesthetists, licensed clinical social workers, clinical psychologists, and registered dieticians or nutrition professionals may also furnish services within their scope of practice and consistent with Medicare benefit rules¹. It is important to note that physical therapists, occupational therapists, and speech-language therapists are not eligible to provide telehealth visits according to CMS. Qualified providers may submit a CMS-1500 claim for telehealth services when performed in accordance with established telehealth guidelines. Whether or not the hospital submits the CMS-1500 claims will depend upon the existing billing arrangements that have been established with these employees.

¹Medicare Telehealth Frequently Asked Questions (FAQs)

If the patient has a positive test result at the time of coding, diagnosis code U07.1, COVID-19, should be assigned for discharges on or after April 1, 2020 along with additional codes to identify the specific manifestation(s) of the infection. If the patient is discharged prior to April 1, 2020, codes for the specific manifestation(s) should be assigned in addition to a secondary diagnosis code of B97.29, Other coronavirus as the cause of diseases classified elsewhere, to report the confirmed COVID-19 infection. You may wish to ask the attending physician to amend the patient’s medical record to acknowledge the positive COVID-19 test.

Due to the technical expertise that is required to obtain an adequate sample for COVID-19 testing, it is appropriate to report a charge for specimen collection when performed in the absence of an E/M visit, such as drive-by specimen collection. Depending upon your location, a low-level E/M visit code such as 99211, Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional, or G0463, Hospital outpatient clinic visit for assessment and management of a patient, may be reported. Specimen collection that is performed by staff of an independent laboratory may assign HCPCS code G2023, Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source.

According to recently published ICD-10-CM Official Coding and Reporting Guidelines for April 1, 2020 through September 30, 2020¹, Z20.828, Contact with and (suspected) exposure to other viral communicable diseases, should be assigned for patients who have had exposure to someone who is confirmed or suspected to have COVID-19, and the patient either tests negative or the test results are unknown. If the patient is suspected to have COVID-19 themselves without a confirmed diagnosis at the time of coding, diagnosis codes describing the patient’s signs and symptoms should be assigned. Only those patients who have a confirmed diagnosis of COVID-19 infection should be assigned a diagnosis code of U07.1, COVID-19, on or after April 1, 2020, or B97.29, Other coronavirus as the cause of diseases classified elsewhere, for dates of service prior to April 1, 2020.

¹CDC – ICD-10-CM Official Coding and Reporting Guidelines

According to recently published ICD-10-CM Official Coding and Reporting Guidelines for April 1, 2020 through September 30, 2020, Z20.828, Contact with and (suspected) exposure to other viral communicable diseases, should be assigned for patients who have had exposure to someone who is confirmed or suspected to have COVID-19, and the patient either tests negative or the test results are unknown.