We’ve collected all the most asked COVID-19 billing questions from those that use our chargemaster and knowledge solutions, and from attendees of past webinars. We then categorized them to make answers easier to find. In this article, we’ll cover FAQs around coding for COVID-19 lab testing.
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As coding and billing regulations continuously change, the content of this article may not be the most up-to-date information and is not intended to take the place of either the written policies or regulations. We encourage participants to review the specific regulations and other interpretive materials as necessary.
We’ve collected all the most asked COVID-19 billing questions from those that use our chargemaster and knowledge solutions, and from attendees of past webinars. We then categorized them to make answers easier to find. In this article, we’ll cover FAQs around coding for COVID-19 lab testing.
Yes. HCPCS code C9803, Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) coronavirus disease [COVID-19], is a conditionally packaged service under the Outpatient Prospective Payment System (OPPS), meaning that C9803 will receive separate payment when it is billed without another primary covered hospital outpatient service. The OPPS will make separate payment for HCPCS code C9803 when it is billed with a clinical diagnostic laboratory test with a status indicator of “A” in the Addendum B file, which includes the lab tests for COVID-19 detection. (05/05/2020)
HCPCS code C9803, Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) coronavirus disease [COVID-19], has been given a retroactive effective date of March 1, 2020. It can be reported for any procedures performed on or after that date which meet the code definition but cannot be reported prior to that date of service. (05/05/2020)
Yes. Specimen collection is not included in the lab test and can therefore be separately reported. However, HCPCS code C9803, Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) coronavirus disease [COVID-19], is a conditionally packaged service under the OPPS, meaning that C9803 will not receive separate payment when billed with an Evaluation & Management (E/M) service; rather the payment will be packaged into the E/M service. (05/05/2020)
Although this question has not officially been addressed by CMS, HCPCS code C9803, Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) coronavirus disease [COVID-19], specifies in the description that it should be used to report specimen collection for SARS-CoV-2, which does not include antibody testing. Vitalware would therefore recommend reporting an alternate code, such as 36415, Collection of venous blood by venipuncture, when collecting blood for a COVID-19 antibody test. (05/05/2020)
HCPCS code C9803, Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) coronavirus disease [COVID-19], is intended to be reported when hospital staff perform specimen collection for COVID-19 testing. There is no requirement that it be collected specifically by laboratory personnel. (05/05/2020)
CMS requires that HCPCS code C9803, Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) coronavirus disease [COVID-19], be reported when specimen collection for COVID-19 testing is performed in a hospital outpatient department. Each commercial payor will have their own guidelines and reimbursement policies related to specimen collection. It will likely be necessary to check with each regarding their specific policies to ensure accurate reimbursement for these services. (05/05/2020)
CPT® and HCPCS codes are not reported on inpatient claims. Inpatient claims for Medicare beneficiaries are assigned a single MS-DRG based upon the ICD-10-CM and ICD-10-PCS codes reported for that encounter. All provided items and services, with some minor exceptions, are packaged into the MS-DRG reimbursement that is received. Even though HCPCS codes are not reported, it is important that hospitals accurately report their costs for all services that are provided during an inpatient encounter. Ultimately, it will be up to each individual hospital to determine which services are included in the typical inpatient room and board charge and which services should be separately billed on the inpatient claim. (05/05/2020)
There has been no guidance published stating which specific revenue codes must be used. Per CMS Manual 100-04, “Medicare Claims Processing Manual”, Chapter 4, Section 20.5, “Where explicit instructions are not provided, providers should report their charges under the revenue code that will result in the charges being assigned to the same cost center to which the cost of those services are assigned in the cost report.” (05/06/2020)
HCPCS code G2023, Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (coronavirus disease [COVID-19]), any specimen source, was created for use when a laboratory technician travels to a non-patient’s home (Bill Type 014X) and collects the specimen for COVID-19 testing.1
HCPCS code C9803, Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) coronavirus disease [COVID-19], was created for instances when a specimen is collected from a registered outpatient of a hospital, including specimen collection procedures that are performed at a temporarily relocated off-campus hospital departments or sites.2 (05/06/2020)
1Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency, Telephone Evaluation and Management (E/M) Services, page 122 (March 18, 2020)
2CMS-5531-IFC, “Medicare and Medicaid Programs, Basic health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program”, pages 195-196 (April 30, 2020)
At this time, as long as medical necessity is met1 and the tests are reported on different dates of service, then it would be appropriate to report HCPCS U0004, 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, making use of high throughput technologies as described by CMS-2020-01-R, without a modifier. There would be no National Correct Coding Initiative (NCCI) edit evoked. (05/06/2020)
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 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 (4/9/2020)
1COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing, pages 5-6 (March 25, 2020)
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. (3/25/2020)
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.
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. (3/25/2020)
The answer will depend upon the reason that a second test was performed. A second lab test should not be reported if that test is performed to confirm the initial results, due to testing issues with the equipment or supplies used to perform the testing, or when a single result is all that is required. A second test may be reported if there is medical necessity for performing a second test. The Special Edition of CPT® Assistant for March 2020 states that COVID-19 testing may be performed on two separate specimens; one obtained from the nasopharynx and one obtained from the oropharynx, based upon recommendations from the Centers for Disease Control (CDC). When COVID-19 testing is performed on two separate specimens, the appropriate code, such as HCPCS code U0002, 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, or 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, would be reported twice, with modifier 59, Distinct Procedural Service, appended to the second test.1 (4/9/2020)
1CPT® Assistant Special Edition, page 3 (March 13, 2020)
According to the CMS FAQ document, when COVID-19 testing is performed using the method specified by 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, the appropriate code to use would be 87635. If testing is performed using a method not described by CPT® 87635, the appropriate code to use would be HCPCS Code U0002, 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC.1 CMS has stated they will recognize both HCPCS code U0002 and CPT® code 87635. However, other payers have the option to make their own determination, and these could vary from payer to payer. (4/9/2020)
1COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing, pages 4-5 (April 10, 2020)
According to special coding guidance published by the AMA, the collection of the specimen by clinical staff in the absence of an evaluation and management (E/M) service 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 recently created two new HCPCS codes that were originally intended to report specimen collection performed by staff of an independent laboratory: G2023, Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source, and 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. In the most recently published edition of the I/OCE Specifications for April 2020, CMS assigned a status indicator of ‘N’ for these two HCPCS codes under the Outpatient Prospective Payment System (OPPS), indicating that the codes could be used by OPPS facilities but that payment for the services would be packaged with other procedures. At the current time, there has been no official guidance from CMS regarding appropriate reporting of COVID-19 specimen collection in an OPPS facility. (4/23/2020)
Specimen collection is not included in the charge for the lab test. However, there has been some conflicting guidance on billing for specimen collection over the past couple of weeks, and we are anticipating further guidance from CMS in the near future on this topic. Due to the technical expertise that is required to obtain an adequate sample for COVID-19 testing, the American Medical Association (AMA) has advised reporting a charge for specimen collection when performed in the absence of an E/M visit, including drive-by specimen collections.1 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 appropriate. CMS recently created two new HCPCS codes that were originally intended to report specimen collection performed by staff of an independent laboratory: G2023, Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source, and 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. In the most recently published edition of the I/OCE Specifications for April 2020, CMS assigned a status indicator of ‘N’ for these two HCPCS codes under the Outpatient Prospective Payment System (OPPS), indicating that the codes could be used by OPPS facilities but that payment for the services would be packaged with other procedures. At the current time, there has been no official guidance from CMS regarding appropriate reporting of COVID-19 specimen collection in an OPPS facility. (4/23/2020)
1Special Coding Advice During COVID-19 Public Health Emergency
CMS has not yet provided clear guidance regarding the use of HCPCS code G2023, Specimen collection for severe acute respiratory syndrome coronavirus 2 (sars-CoV-2) (coronavirus disease [COVID-19]), any specimen source. According to the interim final rule, HCPCS code G2023 was originally intended to be used by independent laboratories to capture the resource utilization of the lab technician who is collecting specimens from homebound or skilled nursing facility patients.1
However, In the most recently published edition of the I/OCE Specifications for April 2020, CMS assigned a status indicator of ‘N’ for these two HCPCS codes under the Outpatient Prospective Payment System (OPPS), indicating that the codes could be used by OPPS facilities but that payment for the services would be packaged with other procedures. At the current time, there has been no official guidance from CMS regarding appropriate reporting of COVID-19 specimen collection in an OPPS facility. According to guidance published by the AMA, a low-level clinic visit, such as CPT® code 99211 or HCPCS code G0463, may be reported when specimen collection is performed without a separately reportable E/M service in order to cover the extra training and supplies necessary for the technician or healthcare provider to obtain an adequate specimen.2 Note that it would not be appropriate to report a low-level clinic visit if the specimen is obtained by the patient, and it would not be appropriate to report a separate low-level clinic visit if specimen collection is performed during the course of an E/M visit. Lab testing may be separately reported, as specimen collection is not included in the lab test itself. (4/23/2020)
1Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency, Interim Final Rule, pages 19256-19258
2Special Coding Advice During CVOID-19 Public Health Emergency
For physician reporting, obtaining a specimen is a component of an E/M visit. According to guidance published by the American Medical Association (AMA), a low-level clinic visit, such as CPT® code 99211, may be reported when specimen collection is performed without a separately reportable E/M service in order to cover the extra training and supplies necessary for the technician or healthcare provider to obtain an adequate specimen.[1] For facility reporting, HCPCS code C9803 may be assigned in addition to an E/M service when a separately reportable E/M service is performed in addition to the testing. However, C9803 is a conditionally packaged service under the OPPS; therefore, reimbursement for the testing will be packaged into the reimbursement for the E/M service. (08/27/2020)
Consider reporting CPT® 87426, Infectious agent antigen detection by immunoassay technique, (eg, enzyme immunoassay [EIA], enzyme-linked immunosorbent assay [ELISA], immunochemiluminometric assay [IMCA]) qualitative or semiquantitative, multiple-step method; severe acute respiratory syndrome coronavirus (eg, SARS-CoV, SARS-CoV-2 [COVID-19]). At this time, there has not been a PLA code published for this nasopharyngeal swab test, but that may change if Abbott has applied for a specific CPT® code to report their test. [1] (08/27/2020)
Yes. 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, was created to enable facilities to capture the extra expenses involved in collecting specimens during the public health emergency (PHE).[1] (10/08/2020)
When the service qualifies as a separately identifiable service, then it would be appropriate to report the services separately. For example, if the patient has the specimen collected at noon and has a second visit at the different location at 3:30, then it would be appropriate to report them separately. Depending upon the type of clinic, either CPT® 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. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services or C9803, Hospital outpatient clinic visit specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) coronavirus disease [COVID-19], any specimen source would be appropriate. [1] (10/08/2020)
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 is reported for each hospital outpatient from whom a specimen is collection for COVID-19 testing. The service is conditionally packaged and only receives separate payment when it is billed without another primary covered hospital outpatient service. [1] (10/08/2020)
