Coding for COVID-19: Updates for the week of April 12
By Carol Hoppe, CPC, CCS-P, CPC-I
MedLucid Solutions

This week has brought more clarity on what various payers want in terms of coding for telehealth services. The challenge is keeping up with every payer every day to see what new changes have come about. As ISMA’s practice management consultant, I’ve worked hard to gather this information in one place, so you do not have to muddle through it all.

First, you will note on the updated COVID-19 Telemedicine Decision Tree on the ISMA COVID-19 Resources page that Anthem now wants POS 02 with either modifier 95 or GT. Previously, they indicated they would recognize but did not require Place of Service (POS) “02"; now, they have stated they will waive member cost share with place of service (POS) 02 and either modifier 95 or GT. If you see members being charged for cost sharing for telehealth (audio-video) services during the PHE, then refile these services with POS 02 to receive the cost-share portion directly from Anthem. Keep in mind that self-funded plans are not required to follow Anthem policies but are strongly encouraged to do so.

Second, Cigna has updated their policy to include modifiers GQ, GT or 95 for telemedicine service via video or telephone. This better aligns with the other payers, as GQ is for asynchronous communication.

Third, WPS GHA Medicare clarified and changed some things previously reported, including:
  • If a provider is performing telehealth from home during the PHE, you can use either their home address or office location. The home address is NOT required in Box 32, as previously reported by WPS. The reference for this is on page 4 in the CMS publication, Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19.
  • For claims already billed with POS 02 where you only got paid at the lower facility rate, WPS recommends doing a Clerical Error Reopening, update the POS code to the location where you normally provide services, and append modifier 95. You will find instructions on the WPS website in the Topic Center under Claims > Guidelines and Resource, how to use the Clerical Error Reopening Form.
  • When billing for online services with codes 99421-99423 or G2061-G2063, which are based on a seven-day time frame, use the date of service when the service was completed. If you have additional communications with the patient during a seven-day period, then increase the code level based on the total number of minutes documented. At the end of the seven days or whenever the service is complete, use that date as the date of service. These codes would only be allowed and paid once every eight days.
  • Use modifier CS to identify services where the E/M resulted in an order for COVID-19 testing or you are performing a test for COVID-19 in the office. If the order is placed through a telemedicine visit, list modifier CS first and then modifier 95, when appropriate. This does not apply to treatment. If you do not report modifier CS, you will not be paid at the full amount, and the patient will be responsible for cost-sharing. [NOTE: Anthem and other payers are also covering the COVID-19 test and visits associated with the COVID-19 test, including visits to determine if testing is needed.]
Fourth, the AMA released two new CPT codes for the COVID-19 antibody test. These codes are effective as of April 10, 2020, and cover a single-step method (86238) and a multiple-step method (86769):

86328 Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single-step method (e.g., reagent strip); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]).

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

For those who missed them, ISMA hosted two free webinars on Billing and Coding for Telehealth Under COVID-19, on April 8 and April 15. The recorded versions are available on the ISMA Online mobile app, which can be downloaded at no charge here.

CARES Supplemental Funding Relief Fund
Finally, you may have already received an email or an actual payment from the CARES Supplemental Funding Relief Fund. These are not loans and will not need to be repaid.

If you are an eligible provider, you will receive payment from the initial $30 billion general distribution within the next week if you haven’t received it already. The automatic payments will come as an ACH via Optum Bank with “HHSPAYMENT” as the payment description. Payments are made based on Taxpayer Identification Numbers and will be sent to a large group’s central billing office.

Providers who have been allocated a payment must sign an attestation confirming receipt of the funds and agree to the Terms and Conditions within 30 days of payment. The CARES Provider Relief Fund Payment Attestation Portal will guide you through accepting the Terms and Conditions and attesting to receipt or rejection of the payments.

Complete details about the relief payments, including a link to the provider portal, may be found on this HHS website.