MM11805 – Summary of Policies in the Calendar Year (CY) 2020 Medicare Physician Fee Schedule (MPFS) Public Health Emergency (PHE) Interim Final Rules

Ordering COVID-19 Diagnostic Laboratory Tests

Having recognized the critical importance of expanding COVID-19 testing during the COVID-19 pandemic PHE, CMS has removed the requirement that certain diagnostic tests are covered only under the order of a treating physician or NPP. This will allow any healthcare professional, authorized to do so under State law, to order COVID-19 diagnostic laboratory tests (including serological and antibody tests). Because the symptoms for coronavirus, influenza, and respiratory syncytial virus (RSV) are often the same, such that concurrent testing for all three viruses is warranted, this provision will also apply to influenza and RSV tests only when they are furnished in conjunction with a medically necessary COVID-19 diagnostic laboratory test to establish or rule out a COVID-19 diagnosis or identify an adaptive immune response to SARSCOV-2.

CMS has made conforming changes to the documentation and record-keeping requirements for lab tests that would not be relevant in the absence of a treating physician’s or NPP’s order. When an order is written for the test, CMS expects the ordering or referring National Provider Identifier information on the claim form under current requirements.

When provided without a physician’s or NPP’s order, the laboratory conducting the test(s) is required to directly notify the patient of the results and meet other applicable test result-reporting requirements. CMS has finalized new specimen collection fees for COVID-19 testing under the MPFS. Physicians and NPPs must use CPT code 99211 to bill for a COVID-19 symptom and exposure assessment and specimen collection provided by clinical staff (such as pharmacists) incident to the physician’s or NPP’s services. This applies to all patients, not just established patients. The direct supervision requirement may be met through virtual presence of the supervising physician or practitioner using interactive audio and video technology. Cost sharing will not apply.

Pharmacists Providing Services Incident to Physician/NPP Services

CMS clarified explicitly the existing policy that pharmacists may provide services incident to, and under the appropriate level of supervision of, the billing physician or NPP, if payment for the services is not made under Medicare Part D. This includes providing the services in accordance with the pharmacist’s state scope of practice and applicable state law.

Source: https://www.cms.gov/files/document/mm11805.pdf