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Are the new COVID-19 lab specimen collection HCPCS codes G2023 and G2024 chargeable by all provider types? Can our hospital bill for these codes?

CMS announced the creation of new COVID-19 lab specimen collection HCPCS codes G2023 and G2024 through their COVID-19 Interim Final Rule, linked below, which was released March 30th. The rule specifies that these codes are only chargeable by independent laboratories and only in instances where trained personnel from the lab travel to collect the specimens from patients who are either homebound or are non-hospital inpatients. There is no language in the rule that allows for these codes to be charged in any other scenario including (but not limited to) testing sites where the patient physically presents to be tested, specimens collected from hospital inpatients, or samples collected from ED patients, etc. It is our interpretation of the rule that HCPCS G2023 should be reported by independent laboratories for specimens collected from homebound or non-hospital inpatients and HCPCS G2024 is reported by independent laboratories when specimens are collected from patients in SNFs and specimens collected on behalf of HHAs.

It is important to note the CMS definition of “homebound” was also expanded under the rule to include:

  1. when a physician attests it is medically contraindicated for a patient to leave the house because of a confirmed or suspected diagnosis of COVID-19; and
  2. when a physician attests it is medically contraindicated for a patient to leave the house because they have a condition that would make them more susceptible to contracting COVID-19.

Homebound status must be clearly documented in the patient’s medical record. A patient who chooses to self-quarantine would not meet the CMS definition of homebound.

CMS Interim Final Rule – “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency”: https://www.cms.gov/files/document/covid-final-ifc.pdf

“This IFC is establishing the following changes to the specimen collection fee policy for the duration of the PHE for the COVID-19 pandemic. We will provide for Medicare payment of a nominal specimen collection fee and associated travel allowance to independent laboratories for collection of specimens related to COVID-19 clinical diagnostic laboratory testing for homebound and non-hospital inpatients. Stakeholders have informed us that access to COVID-19 testing in facilities especially is limited due to the resource costs associated with acquiring the samples in a manner that prevents exposure for patients and health care workers. With patients confined to their homes for their own safety or the safety of others, there is an additional need to have patients tested in their homes and minimize exposure to others. We believe that providing a specimen collection fee for COVID-19 testing during the PHE will provide independent laboratories with additional resources to provide this testing and at the same time help with efforts to limit patients’ exposure to the general population and alleviate patients’ unease with leaving the home.”

“Under this policy, the nominal specimen collection fee for COVID-19 testing for homebound and non-hospital inpatients generally will be $23.46 and for individuals in a SNF or individuals whose samples will be collected by laboratory on behalf of an HHA will be $25.46. Medicare-enrolled independent laboratories can bill Medicare for the specimen collection fee using one of two new HCPCS codes for specimen collection for COVID-19 testing and bill for the travel allowance with the current HCPCS codes set forth in section 60.2 of the Medicare Claims Processing Manual (P9603 and P9604). Our policy will also incorporate the clarification in the definition of homebound as discussed in section II.F. of this IFC, relating to the clarification of homebound status under the Medicare home health benefit.”