As coding and billing regulations continuously change, the content of this article may not be the most up-to-date information and is not intended to take the place of either the written policies or regulations. We encourage participants to review the specific regulations and other interpretive materials as necessary.
During the COVID-19 Public Health Emergency, new codes and coding guidelines are being published almost daily. Keeping up the new codes and understanding how they should be utilized can be challenging, to say the least. To assist with this challenge, we are providing a list of the new codes related to COVID-19 testing and a brief summary of reimbursement rates and intended usage for each code.
Current Procedural Terminology (CPT®) code 86328 was adopted by the American Medical Association (AMA) CPT® Editorial Panel on April 10, 2020 and is effective for use immediately on or after that date. The code was established to report antibody testing performed using a single-step method immunoassay and will allow for tracking of COVID-19 antibody testing. The test is performed using a strip that contains all of the critical components for testing from a blood or serum sample. According to the AMA, 86328 should be reported once for each reagent strip assay. If a single strip tests for multiple antibody classes, only one unit of service should be reported. There is currently no reimbursement information available for this code, but it should be available with no cost-sharing for Medicare beneficiaries using modifier CS, Cost-sharing for specified COVID-19 testing-related services that result in an order for or administration of a COVID-19 test. Payers other than Medicare may have different policies, so it will be important to contact them regarding their specific policies
CPT® code 86769 was also adopted by the AMA CPT® Editorial Panel on April 10, 2020, and is also effective for use immediately. The code describes antibody testing performed using a multiple-step method and is a child code of 86710. This test also utilizes a blood or serum sample but requires a multiple-step process to deliver results. The AMA notes that 86769 should be reported once for each separate assay that is performed. If two different assays are performed on different immunoglobulin classes (e.g., IgG and IgM), 86769 would be reported twice with modifier 59 appended to the second test in order to clarify that a distinct analysis was performed. Reimbursement information for this code is currently unknown, but it should also be available to Medicare beneficiaries without cost-sharing with the addition of modifier CS.
CPT® code 87635 was adopted by the AMA CPT® Editorial Panel during a special session on March 13, 2020 and is available for use on or after that date. This code was established to help report and track testing services related to COVID-19 and to provide reimbursement for COVID-19 testing. Lab tests are evolving rapidly, but 87635 should be used to report testing that is performed using an amplified probe technique. The AMA does note that if tests are performed on two separate specimens, 87635 would be reported twice, appending modifier 59 to the second code to clarify that a separate specimen was tested. Currently, the Centers for Disease Control (CDC) recommends obtaining one specimen from the nasopharynx and a separate specimen from the oropharynx to ensure the most accurate test results. Reimbursement rates for 87635 are currently established at the local level by each Medicare Administrative Contractor (MAC) at either $51.31 or $51.33 depending upon location. Additionally, multiple private payers have followed suit in pricing this drug test at approximately $51.00.
CMS announced the establishment of this code in the Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency Interim Final Rule published in the Federal Register on April 6, 2020. This code was established to allow independent laboratories to report specimen collection for homebound patients. CMS noted that this code should be utilized when trained personnel collect the specimen from patients who are unable to leave their home due to medical contraindication. Use of this code would not be appropriate if the patient collects the specimen for testing. CMS announced a reimbursement rate of $23.46 for this specimen collection. Subsequent to the establishment of this code, there has been discussion to allow facilities and other healthcare providers to use this code for specimen collection. At the current time, this is not an appropriate use of G2023, but we expect CMS to provide updates in the near future. Vitalware will provide updates as they become available.
HCPCS code G2024 was also announced via the Interim Final Rule and was established because current law requires that a higher fee be established for collecting a specimen from an individual in a Skilled Nursing Facility (SNF) or by a laboratory on behalf of a Home Health Agency (HHA). Similar to HCPCS code G2023, this code was intended to be utilized by independent laboratories for specimen collection requiring trained personnel. A reimbursement rate of $25.46 was announced in the interim final rule.
HCPCS code U0001 was created by CMS on February 4, 2020, and may be used for dates of service on or after that date, although the code was not fully implemented by the MACs until April 1, 2020. U0001 is only to be used for the tests developed by the CDC using the CDC test kit. Laboratories that perform testing using a non-CDC test kit will use either CPT® code 87635 or HCPCS code U0002. Because U0001 uses a test kit obtained from the CDC, there is a lower reimbursement rate associated with this code. Local MACs are currently responsible for developing the payment amount for this HCPCS code, which ranges from $35.91 to $35.92. Multiple commercial payers have also announced their intention to follow CMS’ lead with regards to the reimbursement rate for this code.
HCPCS code U0002 was also created by CMS on February 4, 2020, and may similarly be used on or after that date. U0002 uses a non-CDC test kit and allows for testing to be done using any technique. Reimbursement for this code is currently at the local level and ranges from $51.31 to $51.33. When deciding which code to assign for COVID-19 testing, CMS recommends using U0001 for CDC tests, 87635 for tests performed using the amplified probe technique, and U0002 for tests performed using other methodologies not described by CPT® code 87635.
HCPCS code U0003 was announced via CMS Ruling CMS-2020-01-R on April 14, 2020, and is available for immediate use. U0003 should identify tests that would otherwise be identified by CPT® code 87635 that are performed using high-throughput technologies such as the Roche cobas® 6800 System, Roche cobas® 8800 System, Abbott m2000 System, Hologic Panther Fusion® System, GeneXpert® Infinity System, and the NeuMoDx 288™ Molecular System. CMS has announced a reimbursement rate of $100 for tests performed using these high-throughput technologies.
HCPCS code U0004 was also announced via CMS Ruling CMS-2020-01-R on April 14, 2020, and is also available for immediate use. U0004 should identify tests that would otherwise be identified by HCPCS code U0002 that are performed using high-throughput technologies. The reimbursement rate for U0004 is currently $100.