CMS Updates COVID-19 Lab Reporting Requirements
Craneware® Insights Regulatory Updates – CWI1214 (24 March 2020)
CMS Updates COVID-19 Lab Reporting Requirements
CMS posted an update of their Frequently Asked Questions (FAQ) document in which information is provided regarding HCPCS/CPT® codes for SARS-CoV-2/2019-nCoV (COVID-19) testing.
Provider Types Affected
Critical Access Hospitals
Provider-Based Rural Health Clinics
Compliance / Revenue Integrity
Laboratory – General
What You Need to Know
This Craneware Insights article is providing an overview of the CMS and the American Medical Association (AMA) HCPCS/CPT® codes created to report COVID-19 testing.
CMS has created two HCPCS codes, which are effective February 4, 2020:
2019 Novel Coronavirus (2019-nCoV) Real-Time RT-PCR Diagnostic Panel should be used when specimens are sent to the CDC and CDC-approved local/state health department laboratories
2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC should be used when specimens are sent to commercial laboratories, e.g. Quest or LabCorp, and not to the CDC or CDC-approved local/state health department laboratories
HCPCS code U0001 describes COVID-19 testing using the CDC 2019 Novel Coronavirus (2019-ncov) Real Time RT-PCR Diagnostic Panel. HCPCS code U0002 describes non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19) using any technique, multiple types or subtypes (includes all targets).
On March 13, 2020, the AMA posted one new CPT® code for COVID-19 testing:
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
Per the updated CMS FAQ document entitled “COVID-19 FAQs”, the CMS HCPCS codes may be used for lab tests with dates of service on or after February 4, 2020. The AMA CPT® code (87635) may be used for dates of service on or after March 13, 2020. The CMS claims processing system will be able to accept all three codes as of April 1, 2020. CMS is instructing the MACs to hold claims submitted until the first week of April at which time the claims will be released for adjudication.
The FAQ document also offered guidance regarding the circumstances in which each of three codes should be used for reporting purposes:
- Any COVID-19 tests performed with a CDC developed test kit should be billed to Medicare with HCPCS U0001.
- If the laboratory is using the method specified by CPT® code 87635, then report the test with code 87635.
- If the laboratory is using a method not described by CPT® code 87635, then report HCPCS code U0002.
The Medicare Administrative Contractors (MACs) are responsible for developing the payment amounts for the newly created CPT/HCPCS codes until Medicare can establish national payment rates. The current MAC payment rates can be accessed via the following link: https://www.cms.gov/files/document/mac-covid-19-test-pricing.pdf.
In the FAQs document, the question of how to bill Medicare for new types of COVID-19 tests created in the future was answered by CMS with the following: “The appropriate code to use would be HCPCS Code U0002 for COVID-19 test methods that are not specified by either U0001 or 87635. CMS will continue to monitor the types of COVID-19 testing methods and adjust coding as necessary depending on the methodology.”
Providers will need to determine what codes will be accepted by other third-party payers. In a special edition of CPT® Assistant for reporting laboratory testing for coronavirus (SARS-CoV-2) (CPT® Assistant Special Edition, Volume 30, 2020) the AMA states to “contact your local third-party payer directly to determine their specific reporting guidelines” because the use of HCPCS or CPT® codes is “dependent upon the payer to which the claim is being submitted.”
Facilities and providers need to become familiar with Medicare’s billing and coverage guidelines for diagnosing and treating patients with coronavirus. For hospital laboratories in which the COVID-19 testing is processed “in-house”, it will be necessary to determine if the COVID-19 tests are CDC or non-CDC developed in order to assign the appropriate HCPCS code.
Hospitals and providers need to ensure that the new CPT/HCPCS codes are added to their chargemaster(s) and charge capture tools. Staff who enter orders for laboratory tests need to be informed of the newly created codes.
04 February 2020
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