The Families First Coronavirus Response Act: Organizations Prep for Coronavirus Billing

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Original story posted on: April 13, 2020

Swift federal action was recently taken via the Families First Coronavirus Response Act, as public and several private healthcare programs are now covering COVID-19 testing and related services. Healthcare organizations that don’t properly prepare for risk face implications in edits, improper payment, or denials. 

Across the globe, health experts, governments, and other organizations are diligently taking measures to deal with the COVID-19 pandemic. As part of an effort to mitigate the impact of this aggressive viral outbreak in the U.S., swift action has been taken with the Families First Coronavirus Response Act.

Officially in effect on April 2, 2020, the bill requires all public and private healthcare programs to cover COVID-19 testing and related services. With the duration of the COVID-19 crisis still unknown, healthcare organizations must be prepared to properly code and bill, through a comprehensive understanding of the billing guidelines related to the virus, in order to avoid getting caught off-guard by edits, improper payment, or denials.  

Data Accuracy to Reimbursement: Coding for COVID-19

The significance of accurate coding has received universal understanding. Information-sharing continues to circulate in correlation to value-based payments, quality initiatives, and the consequences related to reimbursement if coding is incorrect. At the same time, we are currently living out the original intent of the initial coding system, which is to track data regarding disease processes, patterns, treatment, and effective outcomes of the nation’s response to a public emergency. The COVID-19 crisis has provided us a reminder of the importance of data in successful modeling management of a specific disease. 

Not surprisingly, we have been inundated over the past month with a plethora of information related to the appropriate ICD-10 diagnosis coding for COVID-19. These codes range from screening and virus exposure to presumed cases and confirmed cases with related conditions, and there are specific coding guidelines for each scenario. The American Hospital Association (AHA) and its cooperating parties expeditiously implemented these guidelines. Instructions pertaining to the documentation of the virus and its related activity are ironclad. 

The Families First Coronavirus Response Act allows coinsurance and deductible amounts for Medicare Part B to be waived for services rendered related to COVID-19 testing services. These services are lab tests U0001, U0002, and 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. Also included in the COVID-19-related testing services are evaluation and management (E&M) medical service codes.

The CS (cost-sharing) modifier will signal the Medicare Administrative Contractors (MACs) to pay 100 percent of the allowable cost for the service, and should not be used for services unrelated to COVID-19. A CS modifier should be appended to the E&M code designating medical visits that:

  • Are furnished between March 18, 2020, and the end of the Public Health Emergency (PHE); 
  • Result in an order for or administration of a COVID-19 test; 
  • Are related to furnishing or administering such a test; and/or 
  • Relate to the evaluation of an individual for purposes of determining the need for such a test.

A DR (disaster/emergency-related) condition code should also be applied to COVID-19-related claims. The DR condition code facilitates claim processing and tracks services and items provided to beneficiaries during disaster/emergency situations.

Coding accuracy and claims data are essential components in providing our nation’s healthcare leaders the ability to collect the data needed to effectively combat the coronavirus pandemic. Clearly, accurate reimbursement is a by-product of the correct application of these codes. Equally significant in the fight against COVID-19 is the maintaining of the fiscal and operational capacity of healthcare organizations and hospital systems, leading patient care and recovery efforts.

Programming Note: Listen to Susan Gatehouse report this story live today during Talk Ten Tuesdays, 10-10:30 a.m. EST.

Susan Gatehouse, RHIT, CCS,CPC, AHIMA-Approved ICD-10-CM/PCS Trainer

Susan Gatehouse is the founder and chief executive officer of Axea Solutions. An industry expert in revenue cycle management, Gatehouse established Axea Solutions in 1998, and currently partners with healthcare organizations across the nation, to craft solutions for unique challenges in the dynamic world of healthcare reimbursement and data management.

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