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UPDATE: COVID-19 Specimen Collection for Hospitals & Physicians

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In the CMS-5531-IFC Dated April 30, 2020, CMS confirmed new guidance for specimen collection services and payment. It is important for hospitals and physicians to review the applicable coding guidance summarized below and implement use for claims reporting as soon as possible.

Hospital Outpatient

CMS is creating a new E/M code to support COVID-19 testing specimen collection. The new 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) will be reported when the patient is seen specifically for collection of the respiratory specimen (e.g., via nasopharyngeal (NP) (preferred method), oropharyngeal (OP), nasal mid-turbinate (NMT) or anterior nares). This code will be assigned to APC 5731 Level 1 Minor Procedures and Status Indicator “Q1” (conditionally packaged) under the OPPS for the duration of the PHE. This code will be paid $22.98 national unadjusted rate. The status indicator of Q1 means the outpatient hospital will be paid for the specimen collection and will receive separate payment when it is billed with only a clinical diagnostic laboratory test assigned to a Status Indicator of “A”. With this new service, CMS has indicated beneficiary cost-sharing will not apply as it is a testing-related service.

Hospitals may bill code C9803 when the patient presents to an outpatient clinic, emergency room, or temporary community diagnostic testing site specifically for symptom/exposure assessment and collection of the respiratory specimen. If it turns out the patient has a more significant service performed during the same encounter (same date of service), then only the primary service will be paid and code C8903 will not receive separate payment. This is the standard payment methodology under the HOPPS.

This new guidance for hospital outpatient reporting using new HCPCS code C9803 will replace any use of HCPCS code G2023 and G2024 (see below). CMS did assign Status Indicator “N” to these HCPCS G codes in the IOCE as of April 2020 so in the event outpatient hospital billing occurred with these HCPCS the services would be unconditionally packaged with other services reported on the same claim.

  • G2023 – Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source
  • G2024 – Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), from an individual in a skilled nursing facility or by a laboratory on behalf of a home health agency, any specimen source

Ensure your chargemaster is updated with the new HCPCS code C9803 and discontinue use of G2023 or G2024 so outpatient hospital claims will be paid appropriately. Condition code DR will need to be reported on the claim. Modifier CS is not applicable for specimen collection code.

Independent laboratories will continue to use the HCPCS G codes on their claims when applicable.

Physician and NPP

Physicians and mid-level practitioners will report CPT code 99211 to bill for a COVID-19 symptom and exposure assessment and specimen collection provided by the clinical staff incident to their services. This code may be reported for both new and established patients. Code 99211 is only used when the clinical staff of the physician assesses the patient and collects a specimen. This may be used in instances where the physician directs the patient to come to the office or temporary testing location staffed by the physician staff, and only the clinical staff see the patient. This code will be paid approximately $24. The beneficiary cost-sharing will be waived for this service. Nothing changes when the physician performs a face-to-face evaluation and management visit either in the office or via telehealth and a specimen is collected and sent off to a lab. The providers may also use code 99000 (handling and/or conveyance of specimen for transfer from the office to a laboratory) when a face-to-face visit and specimen collection occurs.

This interim policy will allow physicians and practitioners to bill for services provided by clinical staff to assess symptoms and take specimens for COVID-19 laboratory testing for all patients, not just established patients. A physician or practitioner cannot bill for services provided by auxiliary clinical staff unless those staff meet all the requirements to furnish services “incident to” services, as described in 42 CFR 410.26 and further described in section 60 of Chapter 15 Covered Medical and other Health Services in the Medicare Benefit Policy Manual 100-02. Additionally, under this interim policy, the direct supervision requirement may be met through the virtual presence of the supervising physician or practitioner using interactive audio and video technology.

Providers will need to ensure the POS 11 is used for the professional office setting. Modifier CR will need to be reported since modifier CS is not applicable for the specimen collection service.

We urge providers to review CMS and AMA requirements to ensure an understanding of the requirements addressed in this update.

Sources:

CMS-5531-IFC https://www.cms.gov/files/document/covid-medicare-and-medicaid-ifc2.pdf

COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing as of 4/29/20 https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf