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COVID-19 Coding & Billing Updates

Vaccine Coding and Other Updates Since October 2020

With the arrival of vaccines, the world turned a corner on the fight against COVID-19, and behind the frontlines, mid-revenue cycle personnel have been doing their best to provide support. We're doing our best to share this information as broadly and quickly as we can. The information that follows is captured from a February 4, 2021 webinar presented by Ardith Campbell COC, CPC Manager, Product Content.

Without further ado, here are the major COVID coding changes covered at our most recent webinar.

New ICD-10-CM Codes

These codes are newly released, effective January 1, 2021.

  • Z86.16 Personal history of COVID-19
  • J12.82 Pneumonia due to coronavirus disease 2019
  • M35.81 Multi-system inflammatory syndrome
  • M35.89 Other specified systemic involvement of connective tissue
  • Z11.52 Encounter for screening for COVID-19
  • Z20.822 Contact with and (suspected) exposure to COVID-19

New CPT® and HCPCS Codes

These codes are listed by effective date and do not include anything that was part of the annual update.

Effective November 10, 2020:

  • 87428 Infectious agent antigen detection by immunoassay technique, (eg, enzyme immunoassay [EIA], enzyme-linked immunosorbent assay [ELISA], fluorescence immunoassay [FIA], immunochemiluminometric assay [IMCA]) qualitative or semiquantitative; severe acute respiratory syndrome coronavirus (eg, SARS-CoV, SARS-CoV-2 [COVID-19]) and influenza virus types A and B
  • M0239 Intravenous infusion, bamlanivimab-xxxx, includes infusion and post administration monitoring
  • Q0239 Injection, bamlanivimab-xxxx, 700 mg

Please note that regarding the infectious agent test, the AMA says it doesn’t matter how it’s collected, but is based instead on which test you are doing.

Effective November 21, 2020:

  • M0243 Intravenous infusion, casirivimab and imdevimab includes infusion and post administration monitoring
  • Q0243 Injection, casirivimab and imdevimab, 2400 mg

Vaccines

Effective December 11, 2020:

Pfizer-BioNTech Vaccine

  • 91300 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/ 0.3mL dosage, diluent reconstituted, for intramuscular use
  • 0001A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3mL dosage, diluent reconstituted; first dose
  • 0002A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/0.3mL dosage, diluent reconstituted; second dose

Effective December 18, 2020:

Moderna Vaccine

  • 91301 Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 30 mcg/ 0.3mL dosage, diluent reconstituted, for intramuscular use
  • 0011A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5mL dosage; first dose
  • 0012A Immunization administration by intramuscular injection of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) vaccine, mRNA-LNP, spike protein, preservative free, 100 mcg/0.5mL dosage; second dose

And please keep in mind you will not be billing by the drug, just the administration — the drug itself is currently free during the pandemic.

No Effective Dates Yet for Vaccines Pending Approval

At this moment, there are new codes for both the AstraZeneca and the Janssen (Johnson & Johnson) COVID-19 vaccines, however they may not be used. Their effective date is pending EUA (Emergency Use Authorization) approval. The Janssen vaccine is a single dose, so will only have one code.

COVID-19 Diagnosis Codes: Screening Versus Exposure

Currently a screening code is not appropriate. Everyone should be coded as exposure, since during the pandemic, everybody is presumed to be exposed (rather than possible encounter). So code all individuals with Z20.822. When we are (finally) out of the Public Health Emergency, then the coding guidelines will be updated.

COVID-19 Medication, Treatments, and Vaccines

Only Medicare guidelines are discussed here — other payors may have their own guidelines.

  • CMS placed bamlanivimab and casirivimab/imdevimab infusions under the Medicare Vaccine Benefit
  • Physician order is required
  • Does not follow the infusion / injection hierarchy
  • Medicare Advantage (MA) beneficiary claims for infusion go to original Medicare
  • MA beneficiary claims for other treatments go to MA plan

These infusions are considered part of the vaccine benefit of Part B and should be paid under original Medicare. If your facility has a claim scrubber or payer with edits set up, CMS will expect the single line infusion to follow their usual procedure — so add a no-cost or token charge modifier. For further clarification, you may need to contact your Medicare Administrative Contractor (MAC).

Inpatient Guidelines

  • Inpatient claims: bill similar to influenza vaccine
  • Use Type of Bill 012X INPATIENT HOSPITAL (Medicare Part B ONLY)
  • Date of service is discharge date

“...During the COVID-19 public health emergency (PHE), Medicare will cover and pay for these infusions (when furnished consistent with their respective EUAs) the same way it covers and pays for COVID-19 vaccines....”

In other words, for inpatient claims, you bill for the vaccine or infusion as you would for an influenza vaccine. During the pandemic, Medicare will let you put it on a part B bill.

Current Reimbursement

  • Reimbursement for infusion and post-administration monitoring $309.60
  • Vaccine Administration for 2-dose schedule:
    • First dose: $16.94
    • Second dose: $28.39
  • Vaccine for single-dose only: $28.39

Notice reimbursement for the second dose is higher. This has been done to incentivize providers to get patients in for the second dose. There is no published cost yet for the reimbursement of the vaccine itself (currently free). But they will no doubt update that as the pandemic evolves.

Flexibilities Made Permanent

OPPS

Some changes, made to allow flexibility during the Public Health Emergency, were made permanent in the final Medicare OPPS (Outpatient Prospective Payment System) rules. A few of these items will stick around for awhile (such as non-surgical extended duration therapeutic services which are now general supervision). All of these, however, are subject to your state’s regulations.

MPFS

There are also some different updates to the MPFS (Medicare Physician Fee Schedule) final rules. And some changes to the diagnostic (psychological and neuropathological) testing services supervision, allowing:

  • Nurse Practitioners (NPs)
  • Certified Nurse Specialists (CNSs)
  • Physician Assistants (PAs)
  • Certified Nurse-Midwives (CNMs)

Supervision can now be done by these qualified health care providers... though they must have specialized training or certification in this area. For example, NPs who deliver babies should not be doing the supervision of rorschach tests and such, unless they have dual certification.

Plus, Physical Therapists (PTs) and Occupational Therapists (OTs) may now delegate maintenance therapy to assistants. This delegation is a positive, that could help keep paperwork down. Again, these changes are subject to your state’s regulations.

Miscellaneous

These two items are not exactly COVID-19-related, but are worth noting at this time.

  • The G2211 Visit Complexity moratorium is extended until 2024, while they figure out if it is needed or not. The code has been removed from the MPFS and should not be implemented right now.
  • Most Favored Nation (MFN) remains under litigation and currently has no known time frame of enforcement.

Staying on top of coding and regulatory updates, especially with the rapid pace of change during the pandemic, is essential. We’ll continue to provide resources to the industry in total, as well as in our mid-revenue cycle solutions.

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).