As part of the Public Health Emergency (PHE) for the COVID-19 pandemic and in an effort to be as expansive as possible within the current authorities to have diagnostic testing available to Medicare beneficiaries who need it, in the interim final rule with comment period, CMS is changing the Medicare Fee-for-Service (FFS) Billing rules during the PHE for the COVID-19 pandemic to provide payment to independent laboratories for specimen collection from beneficiaries who are homebound or inpatients not in a hospital for COVID19 testing under certain circumstances.
In general, the Social Security Act (the Act) requires that the Secretary establish a nominal fee for specimen collection for laboratory testing and a fee to cover transportation and personnel expenses (generally referred to as a travel allowance) for trained personnel to collect specimens from homebound patients and inpatients (not in a hospital). The travel allowance is paid only when the nominal specimen collection is also payable. For beneficiaries, neither the annual cash deductible nor the 20 percent coinsurance applies to the specimen collection fees or travel allowance for laboratory tests.
Payment for Specimen Collection for Purposes of COVID-19 Testing
- Who can bill for the Medicare specimen collection fee?
Independent laboratories can bill Medicare through their MAC for the specimen collection fee. 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 of a messenger pick up service. However, the specimen collection fee is not available for tests where a patient collects his or her own specimen.
- How is the IFC changing the Medicare specimen collection and travel allowance policy?
IFC is providing a specimen collection fee and fees for transportation and personnel expenses known as a travel allowance for COVID-19 testing under certain circumstances for the duration of the PHE for the COVID-19 pandemic. The IFC also describes the definition of “homebound” for purposes of our specimen collection policy and allowing for electronic records of mileage for the travel allowance for the duration of the PHE for the COVID-19 pandemic.
- What is the nominal fee for specimen collection for COVID-19 testing for homebound and non-hospital inpatients during the PHE?
The nominal specimen collection fee for COVID-19 testing for homebound and non-hospital inpatients generally is $23.46 and for individuals in a non-covered stay in an SNF or whose samples are collected by a laboratory on behalf of an HHA is $25.46.
- What are the new Level II HCPCS codes for specimen collection for COVID-19 testing?
To identify specimen collection for COVID-19 testing, CMS established two new levels II HCPCS codes effective March 1, 2020. Independent laboratories must use one of these HCPCS codes when billing Medicare for the nominal specimen collection fee for COVID-19 testing for the duration of the PHE for the COVID-19 pandemic.
These HCPCS codes are:
- G2023, specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source
- G2024, specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), from an individual in an SNF or by a laboratory on behalf of an HHA, any specimen source
Note that G2024 is applicable to patients in a non-covered stay in an SNF and not to those residents in Medicare-covered stays (whose bundled lab tests would be covered instead under Part A’s SNF benefit at §1861(h) of the Act).
- How should a laboratory document the miles travel to collect a specimen?
An independent laboratory billing Medicare for the travel allowance is required to log the miles traveled. CMS will not require paper documentation logs that some MACs may have otherwise required; electronic logs can be maintained instead. However, laboratories will need to be able to produce these electronic logs in a form and manner that can be shared with MACs.
- What is the definition of homebound for purposes of our specimen collection policy?
Medicare beneficiaries are considered “confined to the home” (that is, “homebound”) if it is medically contraindicated for the patient to leave the home. When it is medically contraindicated for a patient to leave the home, there exists a normal inability for an individual to leave home, and leaving home safely would require a considerable and taxing effort.
As an example for the PHE for COVID-19 pandemic, this would apply for those patients: (1) where a physician has determined that it is medically contraindicated for a beneficiary to leave the home because he or she has a confirmed or suspected diagnosis of COVID-19; or (2) where a physician has determined that it is medically contraindicated for a beneficiary to leave the home because the patient has a condition that may make the patient more susceptible to contracting COVID-19.
A patient who is exercising “self-quarantine” for his or her own safety during a pandemic outbreak of infectious diseases, such as COVID-19, would not be considered “confined to the home” or “homebound” unless it is also medically contraindicated for the patient to leave the home. If a patient does not have a confirmed or suspected diagnosis of an infectious, pandemic disease such as COVID-19, but the patient’s physician states that it is medically contraindicated for the patient to leave the home because the patient’s condition may make the patient more susceptible to contracting an infectious, pandemic disease, the patient would be considered “confined to the home” or “homebound” for purposes of our specimen collection policy.
Diagnostic Laboratory Services
- How does Medicare pay for clinical diagnostic laboratory tests?
Medicare Part B, which includes a variety of outpatient services, covers medically necessary clinical diagnostic laboratory tests when a doctor or other practitioner orders them. Medically necessary clinical diagnostic laboratory tests are generally not subject to coinsurance or deductible.
- Are there Healthcare Common Procedure Coding System (HCPCS) and Current Procedural Terminology (CPT) codes available for COVID-19 laboratory testing?
CMS has created two HCPCS codes in response to the urgent need to bill for these services. The codes are:
- U0001, CDC 2019-nCoV Real-Time RT-PCR Diagnostic Panel and
- U0002, 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC.
Additionally, the American Medical Association (AMA) Current Procedural Terminology (CPT) Editorial Panel has created CPT code 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). Laboratories can begin billing for the performance of these tests using these codes immediately via standard Fee-for-service billing practices.
- Are all of these codes available for laboratories to use to bill Medicare?
The CMS HCPCS codes will be available on the HCPCS and Clinical Laboratory Fee 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 beginning April 1, 2020, for dates of service on or after March 13, 2020.
- What code should be used for using the CDC test kit to bill Medicare?
The appropriate code to use would be the HCPCS Code U0001 (CDC 2019-nCoV RealTime RT-PCR) Diagnostic Panel). If your laboratory uses the method specified by CPT 87635, the appropriate code to use would be CPT 87635. If your laboratory has a test that uses a method not described by CPT 87635, the appropriate code to use would be HCPCS Code U0002.
Visit our blog section for more billing resources on COVID-19 and Medicare Billing. These resources will help you to prepare your practice and address patient concerns during the COVID-19 pandemic. To get reimbursed for medical services rendered during COVID-19 pandemic, contact Medical Billers and Coders (MBC) at firstname.lastname@example.org