Lab Volume Index
The Lab Volume Index synthesizes billing volume data into a measurement of testing volumes as compared to a pre-Coronavirus testing average ("baseline"). XIFIN analyzed its vast stores of data, representative of four out of five top integrated delivery networks (IDNs) and seven out of the top ten independent laboratories nationwide, to craft the Lab Volume Index.View Index
COVID-19 Test Billing Updates
With information changing frequently, XIFIN is in daily discussions with each of the major payors, to confirm billing code assignment, any billing specific requirements, and reimbursement information. We will continue to provide live updates as we receive them.
UPDATED Jul 30, 2020 | CMS Modifies Relaxed Billing Reqts for COVID-19 Laboratory Tests, Adds CPT 87426
During the COVID-19 Public Health Emergency (PHE), CMS relaxed requirements for a limited number of laboratory tests required for a COVID-19 diagnosis. These tests do not require a practitioner order during the PHE. CMS added a new test to this list: CPT 87426 (Infectious agent antigen detection by immunoassay technique, (e.g., enzyme immunoassay [EIA], enzyme-linked immunosorbent assay [ELISA], immunochemiluminometric assay [IMCA]) qualitative or semiquantitative, multiple-step method; severe acute respiratory syndrome coronavirus (e.g., SARS-CoV, SARS-CoV-2 [COVID-19]).
Any health care professional authorized under state law may order these tests. Medicare will pay for these tests without a written order from the treating physician or other practitioner:
- If an order is not written, you do not need to provide the National Provider Identifier (NPI) of the ordering or referring professional on the claim
- If an order is written, include the NPI of the ordering or referring professional, consistent with current billing guidelines
The Trump administration has ordered hospitals to bypass the Centers for Disease Control and Prevention and send all Covid-19 patient information to a central database in Washington beginning on Wednesday, July 15, 2020. As stated in a COVID Guidance for Hospital Reporting document posted on the HHS website, "As of July 15, 2020, hospitals should no longer report the Covid-19 information in this document to the National Healthcare Safety Network site." Concerns have been expressed about data transparency, and on July 17, a letter signed by more than 100 organizations was sent to Vice President Pence, Ambassador Birx and Secretary Azar recommending that the administration immediately reverse its decision to bypass the Centers for Disease Control and Prevention (CDC) for data collection.
COVID-19 Guidance for Hospital Reporting and FAQs For Hospitals, Hospital Laboratory, and Acute Care Facility Data Reporting
Trump Administration Strips CDC of Control of Coronavirus Data, NYTimes
In its announcement, the American Medical Association (AMA) stated that the new code is meant for “use as the industry standard for accurate reporting and tracking of antigen tests using immunofluorescent or immunochromatographic technique for the detection of biomolecules produced by the SAR-CoV-2 virus.”
RevCycleIntelligence article with additional background and information about descriptors
New federal guidance released today indicates labs will be required to submit a much broader range of demographic COVID-19 testing data, including age, race, ethnicity, sex, patient zip code, type of test performed and the test's result. By August 1, all labs must be able to submit the new data fields to relevant state and local health departments within 24 hours of the results being determined to help with COVID-19 tracking, contact tracing, supply allocation and research. De-identified data will then be sent to the Centers for Disease Control and Prevention on a daily basis. Labs will not be required to report retroactive data.
Labs can report through three electronic mechanisms: directly to state and local governments through existing channels, which will then get de-identified data to the CDC; through a centralized platform, such as the Association of Public Health Labs' AIMS platform, which routes the data to appropriate state and local government and the CDC; and through state and regional health information exchanges.
During the briefing, Admiral Brett Giroir, M.D., assistant secretary for health and lead for COVID-19 testing efforts, added that labs (not manufacturers or distributors) that fail to report the required data could face penalties, enforced by the FDA under Emergency Use Authorization. Penalties could take the form of warning letters or fines, or – in extreme cases – imprisonment.
Laboratory Data Reporting Guidance
Laboratory Data Reporting FAQ
Local Medicare Administrative Contractors (MACs) are responsible for developing the payment amount for claims they receive for these newly created HCPCS codes in their respective jurisdictions until Medicare establishes national payment rates. See the Medicare tab in the Payor Information and Updates section, below.
FAQs address application of OIG's Administrative Enforcement Authorities to arrangements directly connected to the Coronavirus Disease 2019 (COVID-19) Public Health Emergency.
The Health Resources and Services Administration has opened its COVID-19 Uninsured Program Portal, which provides additional information as well as the ability for providers to register. A recorded webinar is available: Getting Started with the HRSA COVID-19 Uninsured Program
Please note the program timelines:
• April 22 – Program Details launch
• April 27 – Sign up period begins for the program
• April 29 – On Demand training starts
• May 6 – Begin submitting claims electronically
• Mid-May – Begin receiving reimbursement
On April 26, the Centers for Medicare & Medicaid Services (CMS) announced that it is reevaluating the amounts that will be paid under its Accelerated Payment Program and suspending its Advance Payment Program to Part B suppliers effective immediately. The agency made this announcement following the successful payment of over $100 billion to health care providers and suppliers through these programs and in light of the $175 billion recently appropriated for health care provider relief payments.
CMS had expanded these temporary loan programs to ensure providers and suppliers had the resources needed to combat the beginning stages of the 2019 Novel Coronavirus (COVID-19). Funding will continue to be available to hospitals and other health care providers on the front lines of the coronavirus response primarily from the Provider Relief Fund.
For an updated fact sheet on the Accelerated and Advance Payment Programs, visit:https://www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf
Today CMS announced Medicare will nearly double payment for certain lab tests that use high-throughput technologies to rapidly diagnose large numbers of 2019 Novel Coronavirus (COVID-19) cases. Medicare will pay laboratories for the tests at $100 effective April 14, 2020, through the duration of the COVID-19 national emergency.
More information can be found on the Medicare tab, below.
April 13, 2020 | Expanded Coverage Announced for Essential Diagnostic Services for COVID Testing, Including Antibody Testing, and Certain Related Services without Cost Sharing for Enrollees in Private Health Coverage
Specifically, today’s announcement implements the requirement for group health plans and group and individual health insurance to cover both diagnostic testing and certain related items and services provided during a medical visit with no cost sharing. This includes urgent care visits, emergency room visits, and in-person or telehealth visits to the doctor’s office that result in an order for or administration of a COVID-19 test. Covered COVID-19 tests include all FDA-authorized COVID-19 diagnostic tests, COVID-19 diagnostic tests that developers request authorization for on an emergency basis, and COVID-19 diagnostic tests developed in and authorized by states. It also ensures that COVID-19 antibody testing will also be covered.
To see the guidance, visit: https://www.cms.gov/files/document/FFCRA-Part-42-FAQs.pdf
April 13, 2020 | AMA CPT Editorial Panel had an emergency meeting on Friday, April 10, 2020, and expedited two new CPT codes for the COVID-19 Antibody Tests
- 86328 Immunoassay for infectious agent antibody(ies), qualitative or semiquantitative, single step method (eg, 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]
AMA also published a Special Edition of the CPT Assistant: SARS-CoV-2 Serologic Laboratory Testing, which provides additional guidance on how to code the two new antibody tests for COVID-19. https://www.ama-assn.org/system/files/2020-04/cpt-assistant-guide-coronavirus-april-2020.pdf
COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers
Relevant information for laboratories begins on p. 18: https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf
Waivers regarding the Stark Law
New Specimen Collection Codes for Laboratories Billing for COVID-19 Testing--see Medicare tab below for details.
Vice President Pence sent a letter to hospital administrators requiring laboratories performing testing for SARS-CoV-2 to report their in-house test results in aggregate via an email to FEMA. Hospitals do NOT need to report testing sent to specific commercial labs. See this link for the contents of the letter. You can access the spreadsheet template, here.
Payor Information and Updates
|Payor||COVID-19 Billing Guidelines||Acceptable CPT Code(s)/HCPCS Code(s)|
|View Guidelines||U0001, U0002, 87635|
|Click on BCBS tab for info||Click on BCBS tab for info|
Diagnostic COVID-19 related laboratory tests (other than COVID-19 test)
U0001, U0002, U0003, U0004, 87635, 86328 , 86769, G2023, G2024
U0001, U0002, 87635
The following CPT codes are accepted for other viral testing to rule out COVID-19:
The applicable COVID-19-related ICD-10 code, or code combination, as appropriate for the date of service, must also be reported on the claim.
UHC accelerated payments program information can be found here
|U0001, U0002, 87635|
|Blue Cross Blue Shield State||COVID-19 Billing Guidelines||Acceptable CPT Code(s)/HCPCS Code(s)|
|Alabama||View Guidelines||U0001, U0002, U0003, U0004, 86328, 86769, 87635, G2023, G2024|
|Alaska||View Guidelines||U0001, U0002, 86328 , 86769, 87635|
|Arizona||View Guidelines||U0001, U0002|
|California||View Anthem Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|California||View Coding Billing Guidelines||U0001, U0002, 87635, G2023, G2024|
|Colorado||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Connecticut||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Delaware||View Guidelines||U0001, U0002, 87635|
|District of Columbia||View Guidelines||U0002, U0003, U0004, 87635|
|Florida||View Guidelines||U0002, U0003, U0004, 87635, G2023, G2024|
|Georgia||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Hawaii||View Guidelines||U0001, U0002, U0003, U0004, 87635, G2023, G2024|
|Idaho||View Guidelines||U0001, U0002, U0003, U0004, 87635, G2023, G2024|
|Illinois||View Guidelines||U0001, U0002, U0003, U0004, 86318, 86328, 86769, 87635, CS Modifier|
|Indiana||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Iowa||View Guidelines||U0001, U0002, U0003, U0004, 86318, 86328, 86769, 87635, G2023, G2024, CS Modifier|
|Kansas||U0001, U0002, U0003, U0004, 87635, G2023, G2024|
|Kentucky||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Louisiana||View Guidelines||U0002, 87635|
|Maine||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Maryland||View Guidelines||U0002, U0003, U0004, 87635|
|Massachusetts||View Guidelines||U0001, U0002, U0003, U0004, 87635, G2023|
|Michigan||U0001, U0002, 87635, G2023, G2024|
|Minnesota||View Guidelines||U0001, U0002, U0003, U0004, 86328, 86769, 87635, G2023, G2024, CS Modifier|
|Mississippi||View Guidelines||U0001, U0002, 87635|
|Missouri||View Anthem Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Missouri||View Blue KC Guidelines||U0001, U0002, 86328 , 86769, 87635|
|Montana||View Guidelines||U0001, U0002, 87635|
|Nebraska||Confirmed via Provider Relations call.||U0001, U0002, 87635|
|Nevada||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|New Hampshire||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|New Jersey||U0001, U0002, U0003, U0004, 86328 , 86769, 87635, G2023, G2024, CS Modifier|
|New Mexico||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635, CS Modifier|
|New York||View Empire BC Guidelines||U0001, U0002, U0003, U0004, 86328, 86769, 87635|
|New York||View Western NY Guidelines||U0001, U0002, 86328, 86769, 87635|
|New York||View Northeastern NY Guidelines||U0001, U0002, 86328, 86769, 87635|
|New York||View Excellus Guidelines||U0001, U0002, 86328, 86769, 87635|
|North Carolina||U0002, 86328, 86769, 87635|
|North Dakota||View Guidelines||U0001, U0002, U0003, U0004, 86318, 86328, 86769, 87635, G2023, G2024, CS Modifier|
|Ohio||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Oklahoma||View Guidelines||U0001, U0002, U0003, U0004, 86318, 86328, 86769, 87635|
|Oregon||View Guidelines||U0001, U0002, U0003, U0004, 86328, 86769, 87635, G2023, G2024, CS Modifier|
|Pennsylvania||View Capital Blue Guidelines||U0001, U0002, 87635, G2023, G2024|
|Pennsylvania||View Highmark HBS Guidelines||U0001, U0002, 87635|
|Pennsylvania||View Highmark BCBS Guidelines||U0001, U0002, 87635|
|Pennsylvania||View Independence Guidelines||U0001, U0002, 87635|
|Puerto Rico||Confirmed via Provider Relations call.||U0001, U0002, 87635|
|Rhode Island||View Guidelines||U0001, U0002, U0003, U0004, 86328, 86769, 87635, G2023, G2024, QW Modifier|
|South Carolina||View Guidelines||U0001, U0002, 86328, 86769, 87635|
|South Dakota||View Guidelines||U0003, U0004, 86318, 86328, 86769, 87635, G2023, G2024, CS Modifier|
|Tennessee||View Guidelines||U0001, U0002, U0003, U0004, 86318, 86328, 86769, 87635|
|Texas||View Guidelines||U0001, U0002, U0003, U0004, 86318, 86328, 86769, 87635, G2023, G2024, CS Modifier|
|Utah||View Guidelines||U0001, U0002, U0003, U0004, 86328, 86769, 87635, G2023, G2024, CS Modifier|
|Vermont||View Guidelines||U0001, U0002, 87635|
|Virginia||View Anthem VA Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Virginia||View Carefirst Guidelines||U0002, U0003, U0004, 87635|
|Washington||View Premera Guidelines||U0001, U0002, 86328 , 86769, 87635|
|Washington||View Regence Guidelines||U0001, U0002, U0003, U0004, 86328, 86769, 87635, G2023, G2024, CS Modifier|
|West Virginia||View Guidelines||U0001, U0002, 87635|
|Wisconsin||View Guidelines||U0001, U0002, U0003, U0004, 86328 , 86769, 87635|
|Wyoming||U0001, U0002, 87635, G2023, G2024|
Local Medicare Administrative Contractors (MACs) are responsible for developing the payment amount for claims they receive for these newly created HCPCS codes in their respective jurisdictions until Medicare establishes national payment rates. The payment amounts are identified below. Source: https://www.cms.gov/files/document/mac-covid-19-test-pricing.pdf (published 5-19-20)
|ALL 12 MAC Jurisdictions||$35.91||$51.31||$100.00||$100.00||$51.31||$42.13||$45.23|
Any health care professional authorized under state law may order tests. Medicare will pay for tests without a written order from the treating physician or other practitioner:
- If an order is not written, an ordering or referring National Provider Identifier (NPI) is not required on the claim
- If an order is written, include the NPI of the ordering or referring professional, consistent with current billing guidelines
April 17, 2020 | ACLA obtains clarifications regarding use of new U-code for high throughput COVID-19 diagnostic testing
4/17/20 ACLA obtains clarifications regarding use of new U-code for high throughput COVID-19 diagnostic testing.
- The effective date of the CMS Ruling and the codes is April 14, 2020. It is not retroactive, so reimbursement for claims submitted to date using HCPCS code U0002 will remain $51.
- A technology that can process more than 200 specimens a day using automatic processing qualifies as a “high-throughput technology,” even if it is used for LDTs and with a manufacturer’s kit, and even if the actual number of tests processed in a given day using the technology is below 200 total (because of low order volume or servicing of the platform). The technologies included in the Ruling were examples, and there was not an intent to exclude a technology that otherwise would meet the definition.
- The expectation is that in almost all cases, a lab using a high-throughput technology for COVID-19 testing would use U0003 (used to “identify tests that would otherwise be identified by CPT code 87635 but for being performed with high throughput technologies”). CMS created U0004 (used to “identify tests that would otherwise be identified by U0002 but for being performed using high throughput technology”) just in case it is needed.
- CMS does not know how the MACs will monitor the appropriate use of U0003 and U0004. The expectation is that laboratories already maintain information that would allow them to “connect the dots at the back end” to support the use of U0003 or U0004, if they were subject to an audit. As usual, it is each laboratory’s responsibility to ensure it codes appropriately.
- CMS representatives said they do not know what would happen when the public health emergency is terminated and whether the codes (and the higher reimbursement) would “switch off.”
- CMS is developing FAQs on these codes and will release them soon.
April 15, 2020 | CMS announces increased reimbursement rates for COVID-19 related testing, introduces two new codes
CMS announces new rate of $100 and provided the following guidance for the two newly introduced codes:
CMS's PAYMENT FOR LABORATORY TESTS FOR THE DETECTION OF SARS–COV–2 OR THE DIAGNOSIS OF THE VIRUS THAT CAUSES COVID–19 MAKING USE OF HIGH THROUGHPUT TECHNOLOGIES
CDLTs making use of high throughput technologies (as defined in this Ruling) and administered during the ongoing emergency period defined in paragraph (1)(B) of section 1135(g) of the Act beginning on or after March 18, 2020, for the detection of SARS–CoV–2 or the diagnosis of the virus that causes COVID–19, are new and involve high throughput machines (which are highly sophisticated equipment) which require more intensive technician training (to ensure the role of extremely skilled personnel) and more time intensive processes (to assure quality). A high throughput technology uses a platform that employs automated processing of more than two hundred specimens a day. Examples of high throughput technology as of April 14, 2020 include but are not limited to technologies marketed on that date as the Roche cobas 6800 System, Roche cobas 8800 System, Abbott m2000 System, Hologic Panther Fusion System, GeneXpert Infinity System, and NeuMoDx 288 Molecular. This training and these processes represent an increase in resources, bringing the total resources required for these tests to $100 (a more accurate payment than the one currently in use via contractor pricing).
These tests are a type of CDLT currently paid for under 3 CMS-Ruling 2020-1-R Medicare Part B. Specifically, the following codes would identify these tests:
U0003: 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, making use of high throughput technologies as described by CMS-2020-01-R.
U0004: 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC, making use of high throughput technologies as described by CMS-2020-01-R.
It is noted that U0003 should identify tests that would otherwise be identified by CPT code 87635 but for being performed with these high throughput technologies. It is further noted that U0004 should identify tests that would otherwise be identified by U0002 but for being performed with these high throughput technologies.
Finally, it is noted that neither U0003 nor U0004 should be used for tests that detect COVID-19 antibodies. CMS intends to promptly evaluate payment for relevant CDLTs for COVID-19 testing that make use of high throughput technologies developed after this issuance upon request for payment at an appropriate rate.
CONCLUSION With regard to CDLTs that make use of high throughput technologies (as defined in this Ruling), are administered during the ongoing emergency period defined in paragraph (1)(B) of section 1135(g) of the Act beginning on or after March 18, 2020, for the detection of SARS–CoV–2 or the diagnosis of the virus that causes COVID–19, and are a type of CDLT currently paid for under Medicare Part B using CPT code 87635 or U0002, such tests, as identified using U0003 or U0004 as appropriate, shall be paid for at the rate of $100. Payment for all other CDLTs remains at the current level. CMS intends to promptly evaluate payment for relevant CDLTs for COVID-19 testing that make use of high throughput technologies developed after this issuance upon request for payment at an appropriate rate.
March 31, 2020 | To identify specimen collection for COVID-19 testing, CMS is establishing two new level II HCPCS codes
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 new 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 a skilled nursing facility or by a laboratory on behalf of a home health agency, any specimen source
CMS has stated, "we created the second Level II HCPCS code, G2024, because section 1834A(b)(5) of the Act and our regulations at § 414.507(f) require a higher fee for collecting a specimen from an individual in a SNF or by a laboratory on behalf of an HHA, as described previously in this section of the IFC. We will issue guidance when the PHE for the COVID-19 pandemic is over and when these codes are no longer valid and terminated in the HCPCS file and/or the CLFS as appropriate. In addition, Medicare payment for transportation and expenses for trained personnel to CMS-1744-IFC 99 collect specimens from homebound patients (as discussed in section II.F. of this IFC, relating to the clarification of homebound status under the Medicare home health benefit) and inpatients (not in a hospital) for purposes of COVID-19 testing will be made in accordance with existing instructions found in the Medicare Claims Processing Manual.
"Independent laboratories must use the existing level II HCPCS codes when billing for the travel allowance, that is, the per mile travel allowance as described by HCPCS code P9603 and the flat rate travel allowance as described by HCPCS code P9604. Additionally, we are clarifying that paper documentation of miles traveled is not required and laboratories can maintain electronic logs with that information. However, laboratories will need to be able to produce these electronic logs in a form and manner that can be shared with MACs."
Source: HHS federal register document, Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the
COVID-19 Public Health Emergency see definitions of code use on pages 98-99.
|States||Website||Accepted CPT/HCPCS Code(s)|
|Alabama||View Resource||U0001, U0002|
|Alaska||View Resource||U0001, U0002|
|Arizona||View Resource||U0001, U0002, U0003, U0004, 86328, 86769, 87635, G2023, G2024, CR Modifier|
|Arkansas||View Resource||U0001, U0002|
NEW: Medicaid California is accepting new code 87426, but has not yet published a rate.
As of 4/22 Medi-Cal is pricing U0003 and U0004 at 100% of Medicare rate without cuts or reductions View Resource
U0001, for providers using the CDC's 2019-nCoV Real-Time RT-PCR Diagnostic Panel test = $35.91
U0002, for providers performing COVID-19 testing by other techniques, not making use of high throughput technologies as described by CMS-2020-01-R = $51.31
U0003, for providers performing COVID-19 testing by DNA or RNA amplified probe technique, making use of high throughput technologies as described by CMS-2020-01-R = $100
U0004, for providers performing COVID-19 testing by other techniques, making use of high throughput technologies as described by CMS-2020-01-R = $100
87635, for providers performing COVID-19 testing by DNA or RNA amplified probe technique, not making use of high throughput technologies as described by CMS-2020-01-R = $51.31
G2023, G2024, QW Modifier
|Colorado||View Resource||U0001, U0002, U0003, U0004, 87635, G2023, G2024|
|Connecticut||View Resource||U0001, U0002|
|Delaware||View Resource||U0001, U0002|
|Florida||View Resource|| |
U0001, U0002, U0003, U0004, 86328, 86769, 87635
|Georgia||View Resource||U0001, U0002, 87635|
|Hawaii||View Resource||U0001, U0002, 87635|
|Idaho||View Resource||U0001, U0002, 87635|
|Illinois||View Resource||U0001, U0002, U0003, U0004, 87635|
|Indiana||View Resource||U0001, U0002, 87635|
|Iowa||U0001, U0002, 87635|
|Kansas||View Resource||U0001, U0002, 87635|
|Kentucky||View Resource||U0001, U0002, U0003, U0004, 87635|
|Maine||View Resource||U0001, U0002, 87635|
|Maryland||View Resource||U0002, 87635|
|Massachusetts||View Resource||U0002, 87635|
|Michigan||View Resource||U0001, U0002, 87635|
|Minnesota||View Resource||U0001, U0002, 87635|
|Mississippi||View Resource||U0001, U0002, U0003, U0004, 87635, G2023, G2024|
|Missouri||View Resource||U0001, U0002, U0003, U0004, 87635, G2023, G2024|
|Montana||View Resource||U0001, U0002, 87635|
|Nebraska||View Resource||U0001, U0002|
|Nevada||View Resource||U0001, U0002, 87635|
|New Hampshire||View Resource||U0001, U0002, 87635|
|New Jersey||View Resource||U0002|
|New Mexico||View Resource||U0001, U0002, 87635|
|New York||View Resource||U0001, U0002|
|North Carolina||View Resource||U0001, U0002, 87635|
|North Dakota||View Resource||U0001, U0002, U0003, U0004, 87635|
|Ohio||View Resource||U0001, U0002, 87635|
|Oklahoma||View Resource||U0001, U0002, U0003, U0004|
|Oregon||View Resource||H0001, U0002, 86328, 86769, 87635|
U0001, U0002, U0003, U0004, 86328, 86769, 87635, QW Modifier
Pricing for antibody tests:
|Rhode Island||View Resource||U0001, U0002, 87635|
|South Carolina||View Resource||U0001, U0002|
|South Dakota||View Resource||U0001, U0002, U0003, U0004|
|Tennessee||View Resource||U0001, U0002, 87635|
|Texas||View Resource||U0001, U0002|
|Utah||View Resource||U0001, U0002, 86318, 86328, 86769, 87635|
|Vermont||View Resource||U0001, U0002, 87635|
|Virginia||View Resource||U0001, U0002|
|Washington||View Resource||U0001, U0002|
|West Virginia||U0001, U0002, 87635, G2023, G2024|
|Wisconsin||View Resource||U0001, U0002, 87635|
|Wyoming||View Resource||U0001, U0002, U0003, U0004, 87635, G2023, G2024|
Due to the emergent nature of the public health concern surrounding the novel coronavirus testing, both the Centers for Medicare and Medicaid Services (CMS) and the American Medical Association (AMA) developed specific billing codes to help increase testing and track new cases.
On February 13, 2020, CMS developed a new Healthcare Common Procedure Coding System (HCPCS) code for providers and laboratories to test patients for SARS-CoV-2. HCPCS code U0001 is used for CDC testing laboratories. On February 29, 2020, the Food and Drug Administration (FDA) issued a new policy for certain laboratories to develop their own validated COVID-19 diagnostic test. HCPCS code U0002 was announced on March 5, 2020, which allows these laboratories to bill for non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19).
On March 13, 2020, the American Medical Association (AMA) Current Procedural Terminology (CPT) Editorial Panel convened in a special meeting and approved a new code to describe the laboratory test for severe acute respiratory syndrome corona-virus 2 (SARS-CoV-2). Although, not included in the 2020 CPT publication, 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; is effective immediately for use to report this test service. It will be included in the 2021 code set in the Microbiology subsection under the Pathology and Laboratory section of the CPT manual.
CARES Act Loan Programs, Laboratory Impact
On Friday March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act was signed into law. It has many sections, but a few in particular affect diagnostic providers. Click the expander button to see information about Medicare’s accelerated/advanced payments, provider eligibility and process, and also access fact sheets and other resources:
Webinar: Received COVID-19 Funding? How to Mitigate & Respond to Enforcement Risks and Government Actions
On Wednesday, July 15, law firm Mintz is hosting a webinar about enforcement risks stemming from COVID-19 relief and stimulus funds. The global pandemic has caused many businesses to apply for grants and/or loans or accept and retain federal funds under the CARES Act and other federally funded relief programs. Mintz’s COVID-19 Compliance & Enforcement Defense Task Force will review how to avoid risk and how to address enforcement when it arises. Learn more and register
One CARES act provision of note is the requirement for providers of COVID-19 diagnostic testing to publish the cash price for the test on their website. The requirement appears to last for the duration of the emergency declaration. The requirement also applies to any “provider of diagnostic testing” for the COVID-19 virus and is not limited to clinical laboratories. Test providers who do not publish the cash price for their testing can be subject to imposition of civil monetary penalties of up to $300 per day.
Paycheck Protection Program
Businesses with less than 500 employees (full and part time, including broadly defined affiliates), and certain companies with more than 500 employees, are eligible for up to $10 million in loans to cover expenses. Loan amount is up to 2.5 times the last year’s average monthly payroll costs (with some limitations), with a two year term, 1% annual interest, and six month interest deferral. No collateral or personal guarantees are required. Loan forgiveness is equal to the expenditures during the first eight weeks of the loan, reduced by certain reductions in employee pay or workforce. Only available through June 30, 2020.
Emergency Injury Disaster Loan Program (EIDL) Grants
Businesses with less than 500 employees (full and part time, including broadly defined affiliates) are eligible for up to $2 million in loans with below market interest rates and up to 30 year terms, with a $10,000 loan advance within 3 days of application.
Mid-Market Loan Program
The CARES Act authorizes the U.S. Treasury Department to make mid-market loans at no more than 2% interest and a term not longer than 5 years, with limitations on staffing changes, stock buybacks and dividends, and imposes other limitations. The program has not yet been established, and businesses should monitor the Treasury Department’s website.
CMS has expanded the Accelerated and Advance Payments Program for Providers and Suppliers during the COVID-19 emergency:
- A broader group of qualified Part A providers and Part B suppliers are eligible for accelerated or advanced payments
- Most eligible providers and suppliers can request up to 100% of Medicare payments for a three month period
- Requests will be processed quickly, with a seven day turnaround goal
- Repayment over 210 days
Additional CARES Act funding can be expected; health care businesses should monitor the HHS and Treasury Department websites for further announcements and prepare by documenting losses arising from COVID-19 circumstances.
The CARES Act also provides a number of tax benefits for eligible employers:
|Retention credit for employees retained but not working because of the coronavirus||Section 2301|
|Deferment of certain social security payments due on wages through 2020||Section 2302|
|Modification to net operating losses for prior years||Section 2303|
|AMT revisions||Section 2305|
|Increased deductions for certain business interest charges||Section 2306|
|Bonus depreciation for certain real estate improvements||Section 2307|
|Advance refunding of certain credits for paid sick time and leave||Section 3605|
Provider Emergency Relief Fund: Immediate infusion of $30 billion into healthcare system https://www.hhs.gov/provider-relief/index.html
Recognizing the importance of delivering funds in a fast and transparent manner, $30 billion is being distributed immediately – with payments arriving via direct deposit beginning April 10, 2020 – to eligible providers throughout the American healthcare system. These are payments, not loans, to healthcare providers, and will not need to be repaid.
All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for the initial $30B rapid distribution.
- Payments to practices that are part of larger medical groups will be sent to the group's central billing office.
- All relief payments are made to the billing organization according to its Taxpayer Identification Number (TIN).
- As a condition to receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.
- This quick dispersal of funds will provide relief to both providers in areas heavily impacted by the COVID-19 pandemic and those providers who are struggling to keep their doors open due to healthy patients delaying care and cancelled elective services.
- If you ceased operation as a result of the COVID-19 pandemic, you are still eligible to receive funds so long as you provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19.
How are payment distributions determined
- Providers will be distributed a portion of the initial $30 billion based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019.
- A provider can estimate their payment by dividing their 2019 Medicare FFS (not including Medicare Advantage) payments they received by $484,000,000,000, and multiply that ratio by $30,000,000,000. Providers can obtain their 2019 Medicare FFS billings from their organization's revenue management system.
- As an example: A community hospital billed Medicare FFS $121 million in 2019. To determine how much they would receive, use this equation:
- $121,000,000/$484,000,000,000 x $30,000,000,000 = $7,500,000
What to do if you are an eligible provider
- HHS has partnered with UnitedHealth Group (UHG) to provide rapid payment to providers eligible for the distribution of the initial $30 billion in funds.
- Providers will be paid via Automated Clearing House account information on file with UHG or the Centers for Medicare & Medicaid Services (CMS).
- The automatic payments will come to providers via Optum Bank with "HHSPAYMENT" as the payment description.
- Providers who normally receive a paper check for reimbursement from CMS, will receive a paper check in the mail for this payment as well, within the next few weeks.
- Within 30 days of receiving the payment, providers must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. The portal for signing the attestation will be open the week of April 13, 2020, and will be linked on this page.
- HHS' payment of this initial tranche of funds is conditioned on the healthcare provider's acceptance of the Terms and Conditions - PDF, which acceptance must occur within 30 days of receipt of payment. Not returning the payment within 30 days of receipt will be viewed as acceptance of the Terms and Conditions. If a provider receives payment and does not wish to comply with these Terms and Conditions, the provider must do the following: contact HHS within 30 days of receipt of payment and then remit the full payment to HHS as instructed. Appropriate contact information will be provided soon.
Is this different than the CMS Accelerated and Advance Payment Program?
Yes. The CMS Accelerated and Advance Payment Program has delivered billions of dollars to healthcare providers to help ensure providers and suppliers have the resources needed to combat the pandemic. The CMS accelerated and advance payments are a loan that providers must pay back.
Priorities for the remaining $70 billion
Targeted distributions are being worked on that will focus on providers in areas particularly impacted by the COVID-19 outbreak, rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.
Section 3709 - Increasing Provider Funding through Immediate Medicare Sequester Relief
- This section provides prompt economic assistance to health care providers on the front lines fighting the COVID-19 virus, helping them to furnish needed care to affected patients. Specifically, this sectionwould temporarily lifts the Medicare sequester, which reduces payments to providers by 2%, from May 1 through December 31, 2020, boosting payments for hospital, physician, nursing home, home health, and other care. The Medicare sequester will be extended by one year beyond current law to provide immediate relief without worsening Medicare’s long-term financial outlook.
Section 3716 - Clarification Regarding Uninsured Individuals
- This section clarifies a section of the Families First Coronavirus Response Act of 2020 (Public Law 116-127) by ensuring that uninsured individuals can receive a COVID-19 test and related service with no cost-sharing in any state Medicaid program that elects to offer such enrollment option.
Section 3717 - Clarification Regarding Coverage of Tests
- This section clarifies a section of the Families First Coronavirus Response Act of 2020 (Public Law 116-127) by ensuring that beneficiaries can receive all tests for COVID-19 in Medicare Part B with no cost-sharing.
Section 3718 - Preventing Medicare Clinical Laboratory Test Payment Reduction
- This section prevents scheduled reductions in Medicare payments for clinical diagnostic laboratory tests furnished to beneficiaries in 2021. It also delays by one year the upcoming reporting period during which laboratories are required to report private payor (PAMA) data.
You can see the full Bill, here.
CMS has issued a Fact Sheet with more information: Expansion of the Accelerated and Advance Payments Program for Providers and suppliers During COVID-19 Emergency
The American Clinical Laboratory Association (ACLA) has issued a statement criticizing the Act's failure to assure fair reimbursement for testing efforts. You can read it and related statements on the association's COVID response efforts page.
COVID-19 Billing Resources and Updates
Additional Laboratory Resources
Supplies Needed for COVID-19 Testing
XIFIN is organizing a "Call For Action" to laboratories that are not performing COVID-19 testing who may have extra inventory of specimen collection swabs and transport media, and who are willing to sell them to laboratories that need them. Click to see the full list of needed supplies and direct contact information.
COVID-19: Steps XIFIN Is Taking
With the Coronavirus Disease 2019 (COVID-19) continuing its spread around the world, we at XIFIN recognize the responsibility we have to our employees, customers, and partners during this critical time. The health and well-being of our team, our clients, and our clients’ employees are of the utmost importance to us.
As a critical partner to your business, we understand that limiting the impact of this health event on our service is imperative. We are keenly focused on our business continuity planning efforts to maintain a safe work environment for our associates and to sustain our business operations.
Security and safety are integral to our products, business processes, and infrastructure. We have a robust, global, integrated Business Continuity Program in place that is managed by a dedicated team of experts who are working hard to keep our operations running smoothly so that we can provide you with the best possible service.
As such, we have activated our Business Continuity Plan, which includes:
XIFIN has initiated its own employer-testing protocol for employees who have been deemed essential personnel. Partnering with a leading California laboratory and XIFIN’s health insurer, voluntary testing was offered to XIFIN employees by physician order. With plans in place to maintain a routine COVID-19 and antibody testing program for its employees, XIFIN’s framework can act as a model to enable the type of monitoring that will maintain employee and public confidence.
We will continue to monitor this fluid situation and will shift workloads as necessary to do what we can to ensure essential services remain fully operative. XIFIN has demonstrated support to our clients in past emergency situations, and in dealing with the present circumstances, we remain unwavering in our efforts to deliver essential services to all our clients. We are keeping those directly affected by this virus in our thoughts, and send our best wishes for health and safety.