COVID-19 Frequently Asked Questions (FAQs) On Medicare

testLaboratories can begin billing for the performance of these tests using these codesimmediately via standard Fee-for-service billing practices.Revised: 4/10/203. Question: Are all of these codes available for laboratories to use to bill Medicare?Answer: Yes. The CMS HCPCS codes will be available on the HCPCS and Clinical LaboratoryFee Schedule (CLFS) file beginning April 1, 2020, for dates of service on or after February 4,2020. The AMA CPT code, 87635 will also be available on the HCPCS and CLFS file beginningApril 1, 2020, for dates of service on or after March 13, 2020.Posted: 3/21/204. Question: My laboratory uses the CDC test kit; what code should we use to bill Medicare?Answer: The appropriate code to use would be HCPCS Code U0001 (CDC 2019-nCoV RealTime RT-PCR) Diagnostic Panel).Posted: 3/21/205. Question: My laboratory does not use the CDC test kit; what code should we use to billMedicare?Answer: If your laboratory uses the method specified by CPT 87635, the appropriate codeto use would be CPT 87635. If your laboratory has a test that uses a method not describedby CPT 87635, the appropriate code to use would be HCPCS Code U0002.Posted: 3/21/206. Question: What code should we use to bill Medicare if new types of COVID-19 tests arecreated in the future?Answer: The appropriate code to use would be HCPCS Code U0002 for COVID-19 testmethods that are not specified by either U0001 or 87635. CMS will continue to monitor thetypes of COVID-19 testing methods and adjust coding as necessary depending on themethodology.Posted: 3/21/207. Question: How will Medicare pay for COVID-19 testing on the CLFS?Answer: Local MACs are responsible for developing the payment amount for claims theyreceive for these newly created HCPCS codes and the CPT code in their respectivejurisdictions until Medicare establishes national payment rates on the CLFS. Please -test-pricing.pdf for more informationon current MAC payment rates. If there are questions or concerns about payments,laboratories should contact their MAC with additional information.For more information on CMS’s procedures for public consultation on payment for newclinical diagnostic laboratory tests on the CLFS, please seeUpdated: 1/7/2021pg. 7

icePayment/ClinicalLabFeeSched/Laboratory Public Meetings.Revised 4/1/208. Question: My laboratory does not use the CDC test kit and will have a delay inimplementing the CPT code 87635 in our billing system. May we bill Medicare using U0002?Answer: Yes. For the time being laboratories may continue to use U0002 to bill Medicarefor tests described by the CPT code. We will provide advance notice if this changes.Posted: 3/21/209. Question: How has Medicare changed the requirements for clinical diagnostic laboratorytesting during the PHE for COVID-19?Answer: As part of the Interim Final Rule with Comment (IFC) published in the May 8, 2020Federal Register, CMS removed, for the duration of the PHE for COVID-19, the requirementthat the clinical diagnostic laboratory tests for COVID-19 and certain related viruses must beordered by a treating physician or non-physician practitioner (NPP) who uses the tests inthe management of the patient’s specific medical problem. Medicare also removed certaindocumentation and recordkeeping requirements associated with orders for these COVID-19and related clinical diagnostic laboratory tests, as these requirements would not be relevantin the absence of a treating physician’s or NPP’s order.As part of the IFC published in the September 2, 2020 Federal Register, CMS revised thispolicy by specifying that each beneficiary may receive Medicare coverage for one COVID-19and related test without the order of a physician or other health practitioner, but Medicarewill require such an order to cover further COVID-19 and related tests. We believe thatbroad COVID-19 testing without the order of any healthcare professional—including testingfor the related conditions identified in the May 8th COVID-19 IFC—may result in abeneficiary not receiving the medical attention and oversight required to ensure thatdiagnosis and treatment is applied consistent with CDC guidelines and other medicalstandards. Therefore, this policy change helps ensure that beneficiaries receive appropriatemedical attention, especially if they need multiple tests. It is also designed to stopfraudsters from performing or billing for unnecessary tests. In addition, to help ensure thatbeneficiaries have broad access to testing, CMS will also pay for tests when ordered by apharmacist or other healthcare professional authorized under applicable state law to orderdiagnostic laboratory tests. Medicare makes payment for services of pharmacists andcertain other healthcare professionals only when they have an arrangement with aphysician or other billing practitioner. These changes allow Medicare to continue to pay forthese tests during the PHE when they are ordered by pharmacists and other healthcareprofessionals without such an arrangement.The list of codes for which these ordering requirements apply can be found atUpdated: 1/7/2021pg. 8

-rsv-codes.pdf. This list does notindicate coverage. Practitioners and laboratories should check with their local MedicareAdministrative Contractor regarding specific questions of coverage.Updated: 12/11/2010. Question: Will Medicare keep requiring an order from a treating physician or NPP for flu orother tests?Answer: Because the symptoms for influenza and COVID-19 might present in the same way,during the PHE each beneficiary may receive Medicare coverage for one COVID-19 andrelated test without the order of a physician or other health practitioner when these testsare furnished in conjunction with a COVID-19 clinical diagnostic test as medicallynecessary in the course of establishing or ruling out a COVID-19 diagnosis. Medicare willrequire, for coverage purposes, an order for all further COVID-19 and related tests, inaccordance with the guidance in FAQ B9. The list of codes for which these orderingrequirements apply can be found at rsv-codes.pdf. This list does not indicate coverage. Practitioners and laboratories shouldcheck with their local Medicare Administrative Contractor regarding specific questions ofcoverage.Updated: 12/11/2011. Question: Does the CMS table “COVID-19, Influenza, and RSV Clinical Diagnostic LaboratoryTests for which Medicare Does Not Require a Practitioner Order during the PHE” list clinicaldiagnostic laboratory test codes that Medicare will cover during the PHE?Answer: This table lists codes that, if otherwise covered by Medicare, do not require atreating practitioner’s order as a condition of Medicare payment for the initial test and, forsubsequent tests, can be ordered by a pharmacist or other healthcare professionalauthorized under applicable state law to order diagnostic laboratory tests. The table shouldnot be interpreted as a statement of coverage for the listed codes. There may be somecodes for which there are local coverage determinations that non-cover or limit coverage ofcertain tests. Practitioners and laboratories should check with their local MedicareAdministrative Contractor regarding specific questions of coverage.Updated: 12/11/2012. Question: Please explain the different codes for use in COVID-19 specimen collection?Answer: Medicare established two codes, G2023 and G2024, for specimen collection forCOVID-19 clinical diagnostic laboratory tests. Independent clinical diagnostic laboratoriescan bill for these services as well as a travel allowance (HCPCS codes P9603 and P9604)when they collect specimens from beneficiaries who are homebound or non-hospital (SNF)Part B inpatients, that is, individuals in a Part B SNF stay and individuals whose samples willbe collected by a laboratory on behalf of an HHA. However, these specimen collection feecodes may not be billed for a hospital or SNF inpatient in a Part A stay, as the costs for testsUpdated: 1/7/2021pg. 9

(including sample collection) for those patients are already paid and covered as part of thestay. Please refer to IFC1 and the related ovid-19-faqs-508.pdfMedicare is also paying for specimen collection by hospital outpatient departments andphysician offices at their locations. Hospital outpatient departments can use new HCPCScode C9803 to bill for a clinic visit dedicated to specimen collection. This service isconditionally packaged and only receives separate payment when it is billed withoutanother primary covered hospital outpatient service or with a clinical diagnostic laboratorytest that is assigned status indicator “A” in Addendum B of the OPPS. Physician offices canuse CPT code 99211 when office clinical staff furnish assessment of symptoms andspecimen collection incident to the billing professionals services for both new andestablished patients. When the specimen collection is performed as part of another serviceor procedure, such as a higher-level visit furnished by the billing practitioner, that higherlevel visit code should be billed and the specimen collection would not be separatelypayable. Physicians can bill for services provided by pharmacist’s incident to theirprofessional services consistent with requirements under 42 CFR 410.26 and state scope ofpractice and license requirements. The specimen collection codes (which do not include CPTcode 99211) are only active during the PHE.New 6/19/2013. Question: If a COVID-19 diagnostic laboratory test is performed prior to a procedure in anHOPD, ASC or office, is it included as part of the procedure?Answer: Currently, under the hospital OPPS all available COVID-19 clinical diagnosticlaboratory tests are paid separately, thus, if a COVID-19 clinical diagnostic laboratory test isperformed prior to a procedure and billed separately, it is not bundled into the payment forthe procedure. Specifically, with regard to the hospital setting, if the hospital is billing forspecimen collection for the COVID-19 clinical diagnostic laboratory test along with anotherhospital service, the payment for the specimen collection would be packaged into that ofthe procedure. If the ASC or physician office has obtained a CLIA certificate, the ASC(enrolled as a laboratory) or physician/Non physician-practitioner office can bill for testsunder the clinical laboratory fee schedule (CLFS) that the certificate permits them toperform, separate from billing for the procedure that is being furnished. Practitioners, ASCs,and labs should check with their local Medicare Administrative Contractor regarding specificquestions of coverage.New 6/19/2014. Question: If a physician/non-physician practitioner (NPP) reports CPT code 99211 “Office orother outpatient visit for the evaluation and management of an established patient thatmay not require the presence of a physician”, for assessment and collection of COVID-19diagnostic laboratory test specimen for a new patient as permitted under Medicare duringUpdated: 1/7/2021pg. 10

the COVID-19 PHE, and the physician/Non-physician practitioner (NPP) subsequently, on adifferent day, furnishes an Evaluation and Management (E/M) visit to the patient for otherreasons, can he/she report a new patient E/M visit code for the subsequent visit?Answer: Yes, in this situation, under the unique circumstances of the PHE, the patient is notconsidered an established patient merely due to the reporting of CPT code 99211 forassessment and collection of COVID-19 specimen for a new patient. We note that if a higherlevel E/M visit is furnished to a new patient at the time of COVID-19 specimen collection,the encounter should be reported using the higher level new patient visit code rather thanCPT code 99211, and in this case the patient would be considered an established patient forthe subsequent visit and a new patient E/M visit code should not be reported until 3 yearshave passed, as specified under the usual billing rules.New: 7/28/2015. Question: Can physicians/NPPs apply the Cost Sharing (CS) modifier to claims for presurgery examination services that include COVID-19 testing?Answer: The CS modifier should not be used when pre-surgery examination services are notpaid separately, for example if particular services are considered to be part of services witha global surgical period, End Stage Renal Disease (ESRD) services with a monthly capitationpayment or maternity package services.During the COVID-19 PHE, the modifier can be reported with separately reported visit codesthat result in an order for or administration of a COVID-19 test, when they are related tofurnishing or administering such a test or are for the evaluation of an individual forpurposes of determining the need for such a test.New: 7/28/20C. Diagnostic Laboratory Services - Serology Testing1. Question: Are there new Current Procedural Terminology (CPT) codes for COVID-19 testing?Answer: On April 10, 2020, the American Medical Association (AMA) CPT Committeeannounced two new CPT codes to report when patients receive blood tests that can detectantibodies for COVID-19. These two codes are: 86328: Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (e.g., reagent strip); severe acute respiratorysyndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]) 86769: Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2)(Coronavirus disease [COVID-19])New: 5/1/202. Question: When will I be able to bill Medicare for these new test codes?Answer: Medicare has updated its billing systems to accept these new test codes.Updated: 1/7/2021pg. 11

New: 5/1/203. Question: My laboratory has a serology test for COVID-19; which CPT code should I use tobill Medicare?Answer: Both new test codes can be used to bill Medicare for COVID-19 serology testingthat can detect antibodies. If your COVID-19 test can be done in a single step, the mostappropriate code to use is 86328. Multi-step antibody testing for COVID-19 can be billedusing 86769.New: 5/1/204. Question: What is the difference between single-step and multi-step antibody test forCOVID-19?Answer: According to the AMA, CPT code 86328 was established for antibody tests using asingle-step method immunoassay. This testing method typically includes a strip with

The specimen collection fee applies if the specimen is collected by trained laboratory personnel from a homebound or non- hospital inpatient and the specimen is a type that would not require only the services o f a messenger pick up service. However, the specimen collection fee is not available for tests where a patient collects his or her own