NEWS ALERT: FY 2021 ICD-10-CM Guidelines Released — COVID-19 Coding Guidance Update

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Original story posted on: July 17, 2020

ICD-10-CM Official Guidelines for Coding and Reporting FY 2021 have been updated and released, noting many changes related to COVID19 and its observation and screening codes.

EDITOR’S NOTE: During recent weeks, the Centers for Medicare & Medicaid Services (CMS) has been announcing revisions to its regulatory requirements on a near-daily basis in an attempt to ease administrative and logistical burdens on providers amid the ongoing COVID-19 pandemic. As such, articles published on one day may later be found to contain outdated information just several days later. RACmonitor.com and ICD10monitor.com are committed to providing comprehensive coverage of these changes as they continue to be made, so please stay tuned as new developments unfold. 



The ICD-10-CM Official Guidelines for Coding and Reporting FY 2021 have been released, and guidance for the COVID-19 pandemic was clarified.

Talk Ten Tuesdays co-host and editorial board member Dr. Erica Remer’s exclusive coverage of COVID-19 coding guidance is now corroborated by the 2021 ICD-10-CM Official Guidelines for the screening for COVID-19.

“During the COVID-19 pandemic, a screening code is generally not appropriate” states the guidelines. “For encounters for COVID-19 testing, including preoperative testing, code as exposure to COVID-19 (guideline I.C.1.g.1.e).” Remer adds if testing was performed and the exposure is ruled out, Z03.818, Encounter for observation for suspected exposure to other biological agents ruled out, could also be appropriate, if the use of that code is reasonable in the first-listed position.

The most significant coding change applies to the observation code Z03.818. New FY2021 Official Guidelines note that although ‘observation codes are primarily to be used as a principal/first-listed diagnosis,’ that ‘An observation code may be assigned as a secondary diagnosis code when the patient is being observed for a condition that is ruled out and is unrelated to the principal/first-listed diagnosis.’ They cite the example of incidental COVID-19 testing for a motor vehicle collision with negative results.

Although these guidelines do not go into effect until Oct. 1, 2020, Dr. Erica Remer advises that the use of the Z11.59 should be discontinued during the pandemic and replaced with Z20.828. Until October 1, Z03.818 is a mandatory principal diagnosis and would not make sense in the inpatient setting.

Programming Note: This is a developing story and ICD10monitor will continue to report on the FY21 ICD-10-CM coding guidance as it is updated and new information concerning any changes becomes available.

FY2021 ICD-10-CM Official Coding and Reporting Guidelines can be found here https://www.cdc.gov/nchs/data/icd/10cmguidelines-FY2021.pdf

Chuck Buck

Chuck Buck is the publisher of ICD10monitor and is the executive producer and program host of Talk Ten Tuesdays.

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