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Immunology 

Revised      86318 

New Code 86328 

New Code 86769 

86318:    Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (eg, reagent strip); 

86328:   severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) 

            (For severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2] [Coronavirus disease {COVID-19}] antibody testing using multiple-step method, use 86769)

86769:   Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) 

       (For severe acute respiratory syndrome coronavirus 2 [SARS-CoV-2] [Coronavirus 

While you are still required to bill the same way you have since 1997 with the 95 or 97 guidelines for IN-PERSON visits, Part B patients are different now when you do it via telehealth. Instead of the history, exam and mdm determining the level of E&M service, you will now use EITHER the M-D-M or the time for TELEHEALTH ONLY on OFFICE VISITS/OUTPATIENT VISIT CODES 99201-99215!

You still need to document your history and exam for record keeping and patient care - but you will not use those for code selection - FOR TELEHEALTH.  You will use the MDM or time.  If you need a ten minute free refresher on MDM (most doctors LOVE this by the way… seriously - I am hearing from clients in the past 2 days saying they really did love it), you can watch my 10 minute video on MDM  free https://youtu.be/pjgb0ISSF6o?list=PLoeUH-Uvw__CTdOBFKAzEpHLF666zTkQH    .  It really simplifies it for doctors and coders. CMS said in the April 6th final Federal Register they are "maintaining" the current rules regarding MDM.  They said something different about time.  

Now - regarding the time. They said on April 6 in the Federal Register they are "finalizing" the times shown in the links on the CMS website they gave. - but, on May 8th, CMS said "Therefore, we are finalizing on an interim basis, for the duration of the PHE for the COVID–19 pandemic, that the typical times for purposes of level selection for an office/outpatient E/M are the times listed in the CPT code descriptor"

WHAT?   On April 6th, they gave us a new set of times and then on April 14th they said we could use either the times in the CPT book or the times in the new chart and on May 8th, they said to use ONLY the times in the CPT book.   

So - ONLY use the times in the CPT book or the MDM for the telehealth visits.

Also - what many doctors and coders do NOT know is that there is a difference between CPT and Medicare when it comes to time.   Medicare is THRESHOLD or MINIMUM times.   CPT is "nearest" time.  I do not for a second believe the CMS rep yesterday was saying use the time RULES in the CPT book as that would be greatly different than the CMS rules.  I do believe he was saying "use the times listed in the CPT book or you can use the times listed in the link in the federal register".   To be clear:  Medicare is minimum times, so a 99213 if using the times in the CPT BOOK would be a minimum 15 minutes.    A 99213 on a commercial patient could be 13 minutes as that is closer to 15 than 10.

You will still use the normal times found in the CPT book for in person visits and then - only if more than half of the visit was spent counseling and/or coordination of care.    Medicare has NOT said you can use only time or MDM alone for in-person visits.  That doesn't happen until 2021.

EFFECTIVE March 31, we have 2 new HCPC codes for specimen collection for LABS only

G2023  Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source    (About $23.46 Medicare payment)

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

BUT WHAT ABOUT PHYSICIAN OFFICES?

IN the upcoming federal register (which you can download at the bottom of this page called April 30 - 5531), CMS said they recognize that physician offices are going through a lot of expense in obtaining samples for tests and Congress did not authorize them to pay non labs for G2023, so they are giving you permission to use 99211 for those.     ON page 188, they say: "  

Therefore, for the duration of the PHE, we will recognize physician and NPP use of CPT code 99211 for all patients, not just patients with whom they have an CMS-5531-IFC 188 established relationship, to bill for a COVID-19 symptom and exposure assessment and specimen collection provided by clinical staff incident to their services. 

For the duration of the COVID-19 PHE, we are therefore finalizing on an interim basis that when the services described by CPT code 99211 for a level 1 E/M visit are furnished for the purpose of a COVID-19 assessment and specimen collection, the code can be billed for both new and established patients. "

Note that both codes say "any source" so don't restrict these only to the nasal swabs.   These are only for trained personnel and not for patients to do their own tests.

1. Question: Are there Healthcare Common Procedure Coding System (HCPCS) and Current Procedural Terminology (CPT) codes available for COVID-19 laboratory testing?
   Answer: Yes, CMS has created two HCPCS codes in response to the urgent need to bill for these services. The codes are:
    
   • U0001, CDC 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.
     Additionally, the American Medical Association (AMA) Current Procedural Terminology (CPT) Editorial Panel has created 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) 

There are many people giving FALSE information that will get you into trouble if you follow their advice.   The ONLY audit that CMS and Medicare is not going to investigate for services performed during this PHE emergency is whether the patient getting a telehealth call or visit is new or established to your practice.  They WILL be auditing whether the service was done via audio-video or whether the patient requested the phone call or not.   CMS, OIG and DOJ have CMPs (Civil Money Penalties) of $11,000 to $22,000 per claim - so do the math folks.... it is not worth it to commit fraud.  If you do plan on committing fraud in your billing, then you better erase your browser history as the fact you KNOW it is fraud will be found out and that makes it criminal on top of civil.

if the data you are using is more than 36 hours old - it is probably OUTDATED.   Yes, changes are happening constantly.  Since April 1st, I have had to update a webinar I taught on that day a total of 7 times... so far.  Do not go by any coding advice regarding telehealth or telemedicine that you received a couple of weeks ago as it's not current.

For instance, if you're using the AMA guide published at first of April - it's outdated.  If you are using data that says to use POS 02 on everything - it's outdated.  If you're using modifier CR - it's outdated.    Check on this page often - as we're updating it daily

  CMS is temporarily waiving requirements that out-of-state practitioners be licensed in the state where they are providing services when they are licensed in another state. CMS will waive the physician or non-physician practitioner licensing requirements when the following four conditions are met: 1) must be enrolled as such in the Medicare program; 2) must possess  a valid license to practice in the state which relates to his or her Medicare enrollment; 3) is furnishing services – whether in person or via telehealth – in a state in which the emergency is occurring in order to contribute to relief efforts in his or her professional capacity; and, 4) is not affirmatively excluded from practice in the state or any other state that is part of the 1135 emergency area.

• In addition to the statutory limitations that apply to 1135-based licensure waivers, an 1135  waiver, when granted by CMS, does not have the effect of waiving state or local licensure requirements or any requirement specified by the state or a local government as a condition for waiving its licensure requirements. Those requirements would continue to apply unless waived by the state. Therefore, in order for the physician or non-physician practitioner to avail him- or herself of the 1135 waiver under the conditions described above, the state also would have to waive its licensure requirements, either individually or categorically, for the type of practice for which the physician or non-physician practitioner is licensed in his or her home state. 

This can be found at:  https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf