Ad reads Insights Email How To Avoid The 5 Pitfalls in Coding Nuclear Medicine, Diagnostic Radiology and Interventional Radiology Services Complimentary Webinar Thursday June 4 2020 - 1pm Et

Webinar: The 5 Pitfalls in Coding Radiology and Nuclear Medicine, Earn 1.5 CEUs

Please join us on Thursday, June 4, 2020, at 1 pm ET, for our 90-minute live webinar, “How to Avoid the 5 Pitfalls In Coding Nuclear Medicine, Diagnostic Radiology, and Interventional Services.”  

The webinar will focus on learning how to avoid coding and compliance risks and how to capture all charges for Nuclear Medicine and Diagnostic and Interventional Radiology. 1.5 CEUs will be awarded to attendees from RCC, RCCIR, AAPC. Read more

Image of tablet as doctor talks on a telehealth appointment

UPDATE: COVID-19 Telehealth, Telemedicine and Physician Supervision Rules

In response to the comments received from the CMS-1744-IFC issued March 26, 2020, there are several updates related to Telehealth and/or Telemedicine and the Physician Supervision Rules. Read more

Image of COVID19 test

UPDATE: COVID-19 Antibody & Antigen Testing

In the CMS-5531-IFC dated April 30, 2020, CMS has stated COVID-19 serology antibody testing will be coverable by the Medicare program because they fall under at least one Medicare benefit category. The serology test that detects antibodies to SARS-CoV-2, the virus that causes COVD-19, may potentially aid in identifying patients who have had an immune response to the current (or prior) infection. To qualify for coverage the serology test will need to be authorized by the Food and Drug Administration (FDA) under the CLIA policy to perform high-complexity testing. FDA authorization does not include those tests permitted under the Emergency Use Authorization (EUA) process as these tests have not been reviewed and approved by the FDA. The COVID testing performed has to be reasonable and necessary for beneficiaries with known (or prior) infection or suspected current (or past) infection to be considered for coverage. This means the provider will need to include on the claim applicable diagnosis code(s) to ensure the test will be paid. CMS is expecting to be billed only once per sample for the antibody test as repeat tests will not be considered medically necessary.

Currently, CMS has not yet posted Clinical Laboratory Fee Schedule (CLFS) amounts for new CPT codes 86328 and 86769, which were created and released by the American Medical Association (AMA) on April 10, 2020. There are approximately 12 laboratories that have received FDA approval (authorization) for the antibody testing so we would expect to see something soon published by CMS regarding expected payment. The following codes are specific to antibody testing:

CPT Code Long Description
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])

Code 86328 is an infectious agent antibody qualitative or semiquantitative immunoassay by single-step method. Only one unit may be reported regardless of the number of antibody classes tested with one reagent strip. If two distinct reagent strip assays (two antibodies) are ordered and performed, then this may be reported as 86328 x1 and 8632859 x1.

Code 86769 is an antibody qualitative or semiquantitative immunoassay by multi-step method. If multiple assays are ordered and performed for antibodies (different immunoglobulin classes) via two distinct multi-step analyses, then report code 86769 x1 and 8676959 x1.

Remember that code 86735 was created specific to detection of SARS-CoV-2 / COVID-19 antigen via respiratory specimens. If a physician orders collection of a nasopharyngeal or oropharyngeal specimen and blood a specimen and both tests performed, then CPT codes may be reported for each distinct test. Report code 86328 (reagent single-step method) or 86769 (multi-step method) with code 86735 when this scenario occurs.

A specimen collection (venipuncture) charge (CPT code 36415) would be appropriate with the new serologic test codes. Remember regardless of the number of blood specimens collected only one unit may be reported.

Finally, in the CMS-5531-IFC, is relaxing requirements for ordering COVID-19 diagnostic laboratory antigen and antibody testing. CMS is allowing two additional changes to be made only during this Public Health Emergency (PHE):

  • COVID-19 test may be covered when ordered by any healthcare professional authorized to do so under state law, and
  • Removing ordering requirements for certain influenza virus and respiratory syncytial virus (common respiratory virus) when furnished in conjunction with a COVID-19 diagnostic test in the course of establishing or ruling out a COVID diagnosis or identifying patients with an adaptive immune response to SARS-CoV-2 (see below link to posted list of laboratory codes allowed)

Providers are reminded, if a test is performed in the absence of an order, CMS expects the performing laboratory to report the results directly to the patient (and treating physician where applicable) as well as continue timely reporting of all test results to local and/or state officials as required. CMS reminds the billing laboratory to continue reporting on claims ordering/referring provider information when an order is present.

We urge providers of service to review CMS and AMA requirements to ensure understanding of the requirements addressed in this update.

Sources:

CMS-5531-IFC https://www.cms.gov/files/document/covid-medicare-and-medicaid-ifc2.pdf

CMS List of lab test codes for COVID-19, Influenza, RSV https://www.cms.gov/files/document/covid-ifc-2-flu-rsv-codes.pdf

AMA has released a special edition CPT Assistant that can be viewed at https://www.ama-assn.org/system/files/2020-04/cpt-assistant-guide-coronavirus-april-2020.pdf

FDA: Laboratories and Manufacturers COVID-19 Tests https://www.fda.gov/medical-devices/emergency-situations-medical-devices/faqs-diagnostic-testing-sars-cov-2#offeringtests

 

Image of swab Coronavirus test

UPDATE: COVID-19 Specimen Collection for Hospitals & Physicians

In the CMS-5531-IFC Dated April 30, 2020, CMS confirmed new guidance for specimen collection services and payment. It is important for hospitals and physicians to review the applicable coding guidance summarized below and implement use for claims reporting as soon as possible.

Hospital Outpatient

CMS is creating a new E/M code to support COVID-19 testing specimen collection. The new HCPCS code C9803 (Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (sars-cov-2) (coronavirus disease [covid-19]), any specimen source) will be reported when the patient is seen specifically for collection of the respiratory specimen (e.g., via nasopharyngeal (NP) (preferred method), oropharyngeal (OP), nasal mid-turbinate (NMT) or anterior nares). This code will be assigned to APC 5731 Level 1 Minor Procedures and Status Indicator “Q1” (conditionally packaged) under the OPPS for the duration of the PHE. This code will be paid $22.98 national unadjusted rate. The status indicator of Q1 means the outpatient hospital will be paid for the specimen collection and will receive separate payment when it is billed with only a clinical diagnostic laboratory test assigned to a Status Indicator of “A”. With this new service, CMS has indicated beneficiary cost-sharing will not apply as it is a testing-related service.

Hospitals may bill code C9803 when the patient presents to an outpatient clinic, emergency room, or temporary community diagnostic testing site specifically for symptom/exposure assessment and collection of the respiratory specimen. If it turns out the patient has a more significant service performed during the same encounter (same date of service), then only the primary service will be paid and code C8903 will not receive separate payment. This is the standard payment methodology under the HOPPS.

This new guidance for hospital outpatient reporting using new HCPCS code C9803 will replace any use of HCPCS code G2023 and G2024 (see below). CMS did assign Status Indicator “N” to these HCPCS G codes in the IOCE as of April 2020 so in the event outpatient hospital billing occurred with these HCPCS the services would be unconditionally packaged with other services reported on the same claim.

  • G2023 – Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source
  • G2024 – Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), from an individual in a skilled nursing facility or by a laboratory on behalf of a home health agency, any specimen source

Ensure your chargemaster is updated with the new HCPCS code C9803 and discontinue use of G2023 or G2024 so outpatient hospital claims will be paid appropriately. Condition code DR will need to be reported on the claim. Modifier CS is not applicable for specimen collection code.

Independent laboratories will continue to use the HCPCS G codes on their claims when applicable.

Physician and NPP

Physicians and mid-level practitioners will report CPT code 99211 to bill for a COVID-19 symptom and exposure assessment and specimen collection provided by the clinical staff incident to their services. This code may be reported for both new and established patients. Code 99211 is only used when the clinical staff of the physician assesses the patient and collects a specimen. This may be used in instances where the physician directs the patient to come to the office or temporary testing location staffed by the physician staff, and only the clinical staff see the patient. This code will be paid approximately $24. The beneficiary cost-sharing will be waived for this service. Nothing changes when the physician performs a face-to-face evaluation and management visit either in the office or via telehealth and a specimen is collected and sent off to a lab. The providers may also use code 99000 (handling and/or conveyance of specimen for transfer from the office to a laboratory) when a face-to-face visit and specimen collection occurs.

This interim policy will allow physicians and practitioners to bill for services provided by clinical staff to assess symptoms and take specimens for COVID-19 laboratory testing for all patients, not just established patients. A physician or practitioner cannot bill for services provided by auxiliary clinical staff unless those staff meet all the requirements to furnish services “incident to” services, as described in 42 CFR 410.26 and further described in section 60 of Chapter 15 Covered Medical and other Health Services in the Medicare Benefit Policy Manual 100-02. Additionally, under this interim policy, the direct supervision requirement may be met through the virtual presence of the supervising physician or practitioner using interactive audio and video technology.

Providers will need to ensure the POS 11 is used for the professional office setting. Modifier CR will need to be reported since modifier CS is not applicable for the specimen collection service.

We urge providers to review CMS and AMA requirements to ensure an understanding of the requirements addressed in this update.

Sources:

CMS-5531-IFC https://www.cms.gov/files/document/covid-medicare-and-medicaid-ifc2.pdf

COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing as of 4/29/20 https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf