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Ask a Rev Cycle Expert: Token or No Charge for COVID-19 Drug Codes?


For the new COVID-19 "drug" codes provided below, should we bill a "token" charge on the claim? Drugs are provided free (at this point), and guidance is "No" charge if provided for free, but would like to confirm proper coding and claim submission as I have seen it referenced both ways, to add a token charge, and to not bill at all!

  • 91300
  • 91301
  • 91302


The answer will be dependent upon whether or not the claims processing software has an edit set up to track for the vaccine and administration, similar to other edits in place for other vaccines and administration. The Centers for Medicare & Medicaid Services (CMS) has stated that their claims processing systems would not require the vaccine on claims while the drug is provided free of charge.

For Medicare claims, you will only need to submit the injection code without the vaccine. For payors that do set up an edit, then you may submit the vaccine with a minimal charge, which is defined as under $1.01.

Publication 100-04 Medicare Claims Processing Manual, Chapter 32 Billing Requirements for Special Services, Subsection 67.2 Institutional billing for No Cost Items

“…For OPPS claims, when a drug is provided at no cost, claims processing edits prevent drug administration charges from being billed when the claim does not contain a covered/billable drug charge. Therefore, for drugs provided at no cost in the hospital outpatient department, providers must report the applicable drug HCPCS code and appropriate units with a token charge of less than $1.01 for the item in the covered charge field and mirror this less than $1.01 amount reported in the noncovered charge field. Providers must also bill the corresponding drug administration charge with the appropriate drug administration CPT or HCPCS code….”

Disclaimer: This information was current at the time of its publishing and is designed to provide accurate information in regard to the subject matter covered. Vitalware does not accept any responsibility or liability with regard to any errors, omissions, misuses, or misinterpretation by the reader. It is not intended to take the place of either the written policies or regulations. We encourage you to review the specific regulations and other interpretive materials as necessary. All CPT® codes are trademarked by the American Medical Association (AMA) and all revenue codes are copyrighted by the American Hospital Association (AHA).