Stay up to date with the latest billing/coding information surrounding the Coronavirus. See all communications organized below by create date.
The CPT Editorial Panel at the AMA has created and approved new COVID-19 vaccine and administration codes for Moderna, Pfizer, and Novavax manufacturers. CMS has the complete list of vaccine information here.
The CPT Editorial Panel at the AMA has created and approved new COVID-19 vaccine and administration codes for Pfizer, Moderna and Janssen manufacturers. See the AMA CPT Category Descriptors here.
The CPT Editorial Panel at the AMA has created and approved two new COVID-19 administration codes for the 3rd doses of Pfizer and Moderna. See the AMA CPT Category Descriptors here.
In anticipation of the expected FDA approval, the AMA has created COVID-19 vaccine and administration codes for Janssen (Johnson & Johnson). See the CPT Assistant Coding Guide here. The FDA has announced that approval for this single-dose vaccine will likely come in late February 2021. Two new CPT codes have been published to describe the vaccine and administration codes:
91303 (Janssen vaccine code) with admin code 0031A
The AMA has also created COVID-19 vaccine and administration codes for AstraZeneca-Oxford. See the CPT Assistant Coding Guide here. The FDA has delayed the approval of this vaccine for now but has stated that approval may happen in April 2021. Three new CPT codes have been published to describe the vaccine and administration codes:
91302 (AstraZeneca vaccine code) with admin codes 0021A (1st dose) and 0022A (2nd dose)
See crosswalk below for additional details:
The above codes are not effective until the FDA approves the emergency authorization. Once approved, CMS will release the codes in the next quarterly codeset update.
The CPT Editorial Panel has approved the first set of COVID-19 vaccine and administration codes. See the CPT Assistant Coding Guide here.
CMS Announces the Permanent Expansion of Medicare Telehealth Services and Improved Provider Payments. See the CMS newsroom announcement here.
Highlights include:
CMS Announces a Comprehensive Strategy for COVID-19 Surge with Hospitals. See the CMS newsroom announcement here.
Highlights include:
HCPC Code | Effective Dates | Paid by Medicare |
U0003 and U0004 | April 14, 2020 and December 31, 2020 | $100.00 |
U0003 and U0004 | Beginning January 1, 2021 - until end of Public Health Emergency | $75.00 |
U0005 | Beginning January 1, 2021 - until end of Public Health Emergency | $25.00 (see requirements listed above) |
Two new CPT Category I Codes have been approved by the CPT Editorial Panel for expedited publication. The AMA has published an updated guide with additional information dated September 8, 2020. Highlights include:
Service Type |
HCPCS Code |
Visit Complexity Associated with Certain Office/Outpatient E/Ms |
GPC1X |
Prolonged Services |
99XXX |
Group Psychotherapy |
90853 |
Neurobehavioral Status Exam |
96121 |
Care Planning for Patients with Cognitive Impairment |
99483 |
Domiciliary, Rest Home, or Custodial Care services |
99334, 99335 |
Home Visits |
99347, 99348 |
Deadlines have been extended for several COVID-19 related programs. CMS is also continuously updating their FAQ document for providers.
CMS has announced flexibilities for several Innovation Center Models. Please see highlights listed below and refer to the comprehensive chart for greater details.
Please note we made a correction to our 5/1/20 post on 5/4/20:
CMS has been providing incremental and evolving updates on their new policies for FQHC/RHC telehealth services and the billing implications of these changes. Below are CMS’s most recent updates.
Revenue Code | HCPCS Code | Modifiers |
052X | G2025 | CG (required) 95 (optional) |
Revenue Code | HCPCS Code | Modifiers |
052X | G2025 | 95 (optional) |
Revenue Code | HCPCS Code | Modifiers |
052X | G0467 (or other appropriate FQHC Specific Payment Code) | N/A |
052X | 99214 (or other FQHC PPS Qualifying Payment Code) | 95 |
052X | G2025 | 95 |
Revenue Code | HCPCS Code | Modifiers |
052X | G2025 | 95 (optional) |
On April 23rd, Congress allocated an additional $75 billion in COVID-19 provider relief grants (in addition to the 100 billion previously announced). On Sunday April 26th, CMS suspended Advanced Payments to Medicare providers. The Advanced Payment Program allowed groups to request an accelerated payment of 90-days’ worth of Medicare claims. CMS would recoup these payments over time.
This move surprised many providers. In a statement, the agency said, “CMS will be reevaluating all pending and new applications for Accelerated Payments in light of historical direct payments made available through the Provider Relief Fund."
Since the Accelerated and Advance Payment Program was expanded on March 28th, CMS said it has paid out roughly $100 billion in accelerated payments.
HHS has not yet announced how it plans to allocate the new $75 billion in new provider relief grant money from Congress.
Health and Human Services (HHS) will reimburse providers for COVID-19 related services for uninsured patients dating back to February 4th, 2020. This money will come out of the initial tranche of $100 billion allocated to healthcare in the CARES Act.
A new web portal will be available on May 6th and providers can request reimbursement through this portal if they have treated or tested an uninsured patient for COVID-19.
HHS will reimburse providers at Medicare rates for these services as long as funding is available. Providers can claim reimbursement after they confirm the patient is uninsured, and if they agree not to balance bill the patient.
HHS expects to start reimbursement of these claims in the middle of May.
CMS had previously announced (on March 28th) an expansion of its Accelerated and Advance Payment program as a result of COVID-19.
This program allows CMS to make a bulk pre-payment of 90 days’ worth of future claim revenue to help groups with cash-flow. CMS then recoups this money over time. More details can be found in our April 2nd update.
CMS just announced they are expanding this program to help groups participating in CPC+ Track 1 and Track 2.
Essentially, eligible groups can now also request advanced payment of their 3rd quarter Care Management Fees.
The deadline to submit a request for these Care Management Fees is Tuesday April 28th, 2020.
Importantly, for groups participating in CPC+, they should use the previously announced process for securing the advanced payment of their claims-based, fee-for-service revenue.
See additional information from AAFP.
Telehealth Services: Defined as audio/visual communication with a patient.
Virtual Communication Services
See additional information from CMS MLN.
Cost Sharing Waiver for COVID-19 Testing and Related Services—CS Modifier
CMS wants everyone that should be tested, to be tested.
CMS wants to eliminate financial barriers to patients being tested for COVID-19.
As a result, patients do not have to pay any co-pay or co-insurance related to the actual testing, nor to the doctor’s visit (whether in-person or telehealth) that resulted in the test being ordered.
The government wants to ensure the doctors get their full, normal payment so the insurers are paying 100% of these visits and tests.
In order to get paid in full, groups must add a CS modifier when billing these services.
Groups should work with their MAC on the process to rebill these services dating back to March 18th.
See additional details from the American Academy of Family Physicians.
On April 10th, CMS announced they will allow telehealth visits to qualify for HCC risk adjustment during the Public Health Emergency.
The remainder of the visit criteria for eligibility for risk adjustment remains the same.
To qualify, the telehealth visit must be provided via an interactive audio and video telecommunications system that permits real-time interactive communication.
These visits should follow CMS’s previously announced guidelines around using the traditional POS and the telehealth modifier “95”.
See additional details from a CMS bulletin.
In an effort to reduce administrative burden and to allow focus on patient care, CMS has announced changes for the 2019 Measurement Year.
The HEDIS submission requirement has been removed for the 2019 Measurement Year.
CMS also removed the requirement for submission of the 2020 Consumer Assessment of Healthcare Providers & Systems (CAHPS) survey for Medicare health and drug plans.
CMS will use last year’s HEDIS measures scores and ratings from the 2020 Star Ratings (based on care delivered in 2018) for the 2021 Star Ratings.
Similarly, CMS will use the CAHPS measures data scores and ratings (from the 2020 Measure-level Star Ratings) for the 2021 Star Ratings.
See additional details from a CMS bulletin.
CMS had extended the deadline for 2019 data submission from March 31st to April 30, 2020.
MIPS eligible physicians that don’t submit their data by April 30th will automatically qualify for extreme and uncontrollable circumstances and will receive neutral payment adjustment for the 2021 MIPS payment year.
Telehealth Services: Defined as audio/visual communication with a patient.
CMS Telehealth
Medicaid Telehealth
Some state Medicaid programs have provided guidance. While there are variations state-to-state, the general approach is:
Bill using T1015 plus appropriate CPT codes as normal
Add Modifier GT to indicate telehealth
Add Modifier CR to indicate catastrophe/disaster related
Use POS 02
Virtual Communication Services: These are not defined as telehealth as they are not performed using real-time audio/visual communication.
CMS
CMS did provide details on Virtual Communication Services, which are covered below.
Previously RHC and FQHCs could only bill for Virtual Communication Services (G0071) in a very limited set of circumstances.
FQHCs and RHCs can now bill for Virtual Communication Services (HCPCS G0071). G0071 includes:
5 minutes or more of virtual (non-face-to-face) communication between an RHC or FQHC practitioner and RHC or FQHC patient; or
5 minutes or more of remote evaluation of recorded video and/or images by an RHC or FQHC practitioner, occurring in lieu of an office visit; or
The services as described by CPT codes 99421-99423.
Online digital evaluation and management for a patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes, 11-20 minutes, or 21 or more minutes.
The services are no longer restricted to patients having prior treatment in the last year, allowing both new and established patients to benefit.
Consent for these services can now be obtained at the time of service.
Effective for services furnished on or after March 1, 2020, CMS will revise the payment amount for HCPCS G0071 to reflect an average of the national non-facility payment rates for G2012, G2010, and 99421-99423.
Medicaid
Again, state-to-state requirements vary, but in general the guidelines are:
Virtual Communication Services (99421-99423, G0071, 98966-98968) are reimbursable.
The POS for these services should be:
FQHC POS 50
RHC POS 72
Modifiers
These should be billed with Modifier CR (catastrophe/disaster related) to relax frequency limitations defined in the code definitions.
86328: Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (eg, reagent strip); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])
86769: Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])
Telehealth Visits: Clarifying Guidance on Place of Service (POS) 02 vs Modifier 95
CMS is encouraging groups to provide telehealth services.
CMS has significantly expanded the types of services that can be provide via telehealth.
The technology required to perform these services has been broadened, however the requirement remains that the technology includes audio and visual. A phone call alone is not sufficient for a telehealth service.
CMS will be reimbursing physicians for these services at the same rate as an in-person visit.
CMS’s initial guidance was to use POS 02 for these telehealth visits.
Code |
Description |
Non-Facility Rate |
99441 |
Telephone call 5-10 minutes |
$14.44 |
99442 |
Telephone call 11-20 minutes |
$28.15 |
99443 |
Telephone call 12-30 minutes |
$41.14 |
Modifier and POS Requirements:
Since these codes imply the use of communication technology to provide the service, there is no need for POS 02.
CMS recommends billing with the place of service that you would use for a face-to-face visit.
CMS will also allow reimbursement for telephone calls for registered dieticians, social workers, speech language pathologists and physical and occupational therapists.
These individuals should use the following codes:
Code |
Description |
Non-Facility Rate |
98966 |
Telephone call 5-10 minutes |
$13.32 |
98967 |
Telephone call 11-20 minutes |
$26.64 |
98968 |
Telephone call 21-30 minutes |
$39.60 |
Modifier and POS Requirements:
Since these codes imply the use of communication technology to provide the service, there is no need for POS 02.
CMS recommends billing with the place of service that you would use for a face-to-face visit.
Virtual Check Ins
CMS will continue to allow and reimburse for Virtual Check Ins.
The policies around these codes remains largely unchanged, except they can be used for both new and established patients.
Code |
Description |
Non-Facility Rate |
G2010 |
Remote evaluation of recorded video and/or image |
$12.27 |
G2012 |
Brief communication technology-based service 5-10 minutes not related to an E/M visit in last 7 days, nor an incoming E/M visit within 24 hours |
$14.80 |
Modifier and POS Requirements:
CMS initially required place of service 02 (March 17th).
Since these codes imply the use of communication technology to provide the service, there is no need for POS 02.
CMS recommends billing with the place of service that you would use for a face-to-face visit.
Patient Communication via Patient Portal (CMS Defines these as E-Visits)
CMS will continue to reimburse for patient communications conducted via an on-line portal.
These services have largely remained unchanged as a result of the PHE.
The following codes are for physicians or other qualified health professionals:
Code |
Description |
Non-Facility Rate |
99421 |
5-10 minutes |
$15.52 |
99422 |
11-20 minutes |
$31.04 |
99423 |
21-30 minutes |
$50.16 |
The following codes are for qualified non-physicians (may not report E/M):
Code |
Description |
Non-Facility Rate |
G2061 |
5-10 minutes |
$13.70 |
G2062 |
11-20 minutes |
$24.11 |
G2063 |
21-30 minutes |
$37.81 |
Modifier and POS Requirements:
CMS initially required place of service 02 (March 17th)
Since these codes imply the use of communication technology to provide the service, there is no need for POS 02.
CMS recommends billing with the place of service that you would use for a face-to-face visit.
Telehealth Services for RHC and FQHC
CMS is encouraging more telehealth services to be provided during the PHE.
Previously RHC and FQHCs could only bill for virtual communication services (G0071) in a very limited set of circumstances.
CMS is expanding the types of services that can be performed remotely to include those services covered by CPT codes 99421-99432 (E-Visits).
CMS will also revise the payment amount of G0071 to reflect this expansion of services and it will be paid at the average national non-facility amount for codes G2012, G2010, and 99421-99423.
All virtual communication services billable using code G0071 will also be available to new patients that have not been seen in the RHC or FQHC within the previous 12 months.
CMS will reimburse medical groups that collect the throat swab for the purposes of collecting the specimen for sending to an outside lab for testing.
Groups that perform these services can utilize one of these codes depending on the circumstances.
99000- Handling and/or conveyance of specimen for transfer from office to a lab
99001- Handling and/or conveyance of the specimen for transfer from the patient, in location other than a physician's office, to a laboratory.
99211- Outpatient visit “that may not require the presence of a physician”
CMS has also updated the Clinical Laboratory Fee Schedule to include two new codes for specimen collection: G2023 and G2024.
These codes are billable by clinical diagnostic laboratories that perform the specimen collection.
CMS has announced guidance of ICD-10 coding for COVID-19 to try and ensure consistency in how diagnoses are being captured. This will help efforts to track and eventually research the disease.
Up until April 1st, CMS is recommending groups use the diagnosis code of B97.29 (other coronavirus as the cause of diseases classified elsewhere) for COVID-19.
Effective April 1st, the CDC is requesting groups use a newly developed ICD-10 code (U07.1) that is specific for COVID-19.
This diagnosis code would be combined with other codes that more fully describe the patient’s condition. Examples include:
J12.89 (other viral pneumonia)
J20.8 (acute bronchitis due to other specified organisms)
J80 (acute respiratory distress syndrome)
J98.8 (other specified respiratory disorders)
CMS is advising groups not to use B34.2 (coronavirus infection, unspecified) because COVID-19 is not unspecified.
Additionally, official coding has been updated to include the recommendation that groups use the billable ICD-10 code Z11.59 to specify the diagnosis of encounters for screening the viral disease.
Specifically, this should be used when asymptomatic individuals who are being screened for COVID-19 and have no known exposure to the virus, and the test results are either unknown or negative.
CMS announced on March 28th an expansion of its Accelerated and Advance Payment program as a result of COVID-19.
The expansion is part of the recently-enacted Coronavirus Aid, Relief, and Economic Security (CARES) Act.
Accelerated and Advance Medicare payments was originally designed to address emergency funding of cash flow issues in areas where natural disasters have occurred.
During the COVID-19 crisis, CMS is expanding the program to include all Medicare providers and suppliers throughout the country.
The program allows CMS to make a bulk pre-payment of 90 days’ worth of future claim revenue to help groups with cash-flow. CMS then recoups this money over time.
At a high level, the program works like this:
1. The Medical Group/Hospital completes an application through their Medicare Administrative Contractor (MAC).
2. CMS makes a bulk payment of 3 months’ worth of typical CMS claim payments.
3. Groups continue to submit claims and get paid during the time of crisis (120 days)
4. Starting 120 days after the bulk payment, the group’s claims start being deducted from the amount of bulk payment.
5. This process of new claims being unpaid to offset the bulk payment will continue for 210 days for medical groups (longer for hospitals)
6. At the end of the 210 day timeframe, groups must repay the any outstanding balance in full at that time.
The specific details of the program are outlined in the Medicare Fact Sheet.
RCxRules has been closely monitoring the COVID-19 outbreak. We continue to have great appreciation for all that our customers are doing to help their patients and their communities. We are trying to do our small part by focusing on COVID-19’s impact on physician group’s billing and coding practices.
This is the first in a series of communications that we'll be distributing on this topic.
This communication is broken into two parts:
What is CMS doing in response to COVID-19?
How does the CMS response impact billing and coding?
As a result of COVID-19, CMS has responded in several ways. At a high level, CMS is attempting to do the following:
Outlined below are more details on the specific actions CMS has taken to support each of these objectives.
CMS and the AMA are introducing new codes on April 1st that should be used going forward and can also be used for dates of service going back to Feb 4th for HCPCS and March 13th for the CPT code.
Organizations providing the laboratory services should use these codes for all COVID-19 tests.
CMS is waiving the patient’s responsibility for coinsurance and deductibles for COVID-19 tests.
CMS is also waiving the patient’s responsibility for coinsurance and deductibles for the medical visit that resulted in the test being ordered.We are certainly living in challenging and uncertain times.
While the outbreak of COVID-19 is impacting everyone, the two groups most powerfully impacted are the patients with the virus and healthcare organizations caring for them.
On behalf of the entire RCxRules team, I want to thank you for everything you and your organization are doing to help this country navigate this crisis. We are fortunate to have the best healthcare delivery system in the world. Sometimes, as citizens, we may take this for granted. In light of current events, everyone should be grateful and appreciative of the skill and dedication of the care teams across the country. Our industry has risen to challenges before, and I remain optimistic we will meet this challenge, as well.
At RCxRules, we plan on doing our part to continue to support you through this difficult time. The vast majority of our Support Services are already delivered remotely. As a result, our Service team staffing, our technical infrastructure, and our Product Development operations position RCxRules well for normal operations. We will continue to monitor this developing situation with a strong focus on providing the highest level of support and service.
In so many ways, healthcare workers are on the front lines and will be foundational to getting us through this crisis. Thank you very much for all you are doing. We truly appreciate it.
Stay safe.
Sincerely,
Stephen C Gorman
CMS's Virtual Toolkit for their latest materials on COVID-19