5 Steps Prevent Overcharging, Miscoding COVID-19 Testing

If your practice is testing patients for COVID-19, you’ve got a bunch of new codes and payment rules that you need to follow, so you get paid on time, every time – without violating kit reimbursement law.

In the past few weeks, CMS has released a significant amount of guidance on COVID-19 coding and co-pay regulations for encounters involving or resulting in testing for the coronavirus. Adhere to these steps to ensure you implement the right strategies for compliant COVID-19 diagnostic coding and reimbursement.

Check Payer Supply System Requirements

Medicare and some private payers mandate using HCPCS level II supply codes over CPT codes. But there are third party payers that require you report CPT codes to receive reimbursement for supplies. Now you have both options to report tests performed in your office.

In addition to two HCPCS level II diagnostic testing codes, you also have a newly released CPT code. Check your individual payer guidelines to determine whether they require HCPCS or CPT codes—just be sure not to report both on the same claim.

Manually Update CPT Code in Your EMR

If you’ve been hunting for the COVID-19 test code in your CPT 2020 book, you should end your effort. According to the AMA, the new code will appear in code books beginning in 2021.

There is a current unpublished code that you’ll want to add in your billing systems. On an emergency basis, the AMA gave you a new CPT code for COVID-19 testing claims: 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).

Consider Test Type to Choose Between U0001 and U0002

You now have two HCPCS level II supply codes to select from when billing for a test performed in your office. Review the supply box information to determine the code you should use. Here’s how:

CDC test kit (U0001). You should report HCPCS code U0001 to bill only for COVID-19 diagnostic tests that use the official CDC test kit—the 2019 Novel Coronavirus Real-Time RT-PCR Diagnostic Test Panel.
- IMPORTANT: While CMS created the new code in February, you should have been holding claims until recently. Medicare’s claims processing system started accepting this code on April 1, 2020 for claims with dates of service beginning February 4, 2020.

Non-CDC lab test (U0002). For non-CDC lab tests for COVID-19 (also called SARS-CoV-2/2019-nCoV), you should report code U0002 instead of U0001. The CDC added the second new HCPCS code to accommodate a wider variety of coronavirus test kits such as hospital university self-created testing methods.

Use Modifier CS to Identify Cost-Sharing Waivers

You should use modifier CS (Catastrophe/disaster related) on certain E/M services that result in testing a Medicare patient for COVID-19. CMS does not require modifier CR on telehealth services (modifier 95).

On April 7^th, CMS released guidance for providers to append modifier CS (Catastrophe/disaster related) to certain E/M services that result in (or assess the need for) a coronavirus test. When a provider orders or administers a coronavirus test (codes U0001, U0002, or 87635), the Families First Coronavirus Response Act allows for the waiver of cost-sharing (i.e. copays) for Medicare Part B claims.

Appending modifier CS ensures that you will be reimbursed in full—100 percent of the amount of the claim, including the amount that would have been paid by the patient. This includes qualifying E/M services dated March 18, 2020 and later. You can append the modifier to any of these services:

Office and other outpatient services
Hospital observation services
Emergency department services
Nursing facility services
Domiciliary, rest home, or custodial care services
Home services
Online digital E/M services

Because you will be reimbursed in full, do not charge Medicare patients any out-of-pocket amounts for these services when using modifier CS. Also note that a patient does not need to test positive to use modifier CS on their testing claim.

What about claims that you’ve already submitted between March 18^thand now? You may resubmit those claims with the added modifier CS if you contact your MAC administrator before you do so.

Focus on Testing Steps to Identify Antibody Test Code

To be clear, the FDA has not yet approved any antibody tests for COVID-19. They have given one test—from Cellex, Inc.—emergency use authorization only. On April 10, the AMA did release two new codes for COVID-19 antibody testing. Select the code based on the number of steps in the testing process:

Single Step Testing Method (86328): For a single step testing method, such as a reagent strip, use code 86328 (Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (eg, reagent strip); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease)

Multi-Step Method (86769) For a multi-step method, use 86769 (Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease).

To be paid accurately and fully, it’s imperative that you 1) identify the number of steps in the testing process, not the number of antibodies you’re testing for, 2) know the number of strips used, and 3) apply a modifier when needed. Here are some typical scenarios that you will face along with proper billing to help you file claims without receiving partial payment or denials.

Single Step Test for multiple antibodies using one reagent strip. Report code 86328. Regardless of the number of antibodies reported on the strip, you are still using a single strip.

Single Step Test for multiple antibodies using multiple reagent strips. You would report 86328 once for each strip tested. Then, you’d append modifier 59 (Distinct procedural service) to the code for the second reagent strip test to indicate a separate analysis.

Multiple Step Test for multiple antibodies using one reagent strip. Report 86769 as one unit of service, regardless of the number of the antibodies that you tested the patient for.

Multiple Step Test for multiple antibodies using multiple reagent strips. If you used multiple test strips, you’d code 86769 once for each of them, then append modifier 59 to indicate a separate analysis.