1) The CARES Act does not require that COVID be the primary diagnosis. The particular payor
we are having issues with website does state that COVID must be the primary diagnosis but that
imposes a requirement that is not contained in the CARES Act. Should the coder change their
coding based on this payor?
This question was addressed in the presentation, we agree with the AHIMA and AHA positions that
the coding should be done compliantly without question. We cannot or will not advise coders to
change the sequencing of the coding for any particular payor. If you are having issues with a
specific payor, you may want to consider an internal process in conjunction with your business
office. NJHA supports only compliant coding and following the Official Coding Guidelines.
2) We are having issues billing Medicaid for COVID testing. Can you offer any other insight that
might help us?
This question is similar to question 1, and the advice is still the same, we cannot or will not advise
coders to change the sequencing of the coding for any particular payor. If you are having issues
with a specific payor, you may want to consider an internal process in conjunction with your
business office. NJHA supports only compliant coding and following the Official Coding Guidelines.
3) If a COVID lab test is being done because patient has presented with a symptom like fever or
cough and the test is negative (and they indicate no known exposure) what COVID screening
code is used?
When a COVID lab test is being done because of symptoms and the test is negative, code the
symptoms as the Z20.828. See Guideline I.C.21.c.1, in a pandemic everyone is assumed to be
exposed.
4) If a patient is getting a covid test for the soul purpose of having surgery since it is required,
would the code Z11.59 be the only code used or would code Z01818 be included? Of course, if it
comesback positive, I would use U07.1.
If there is a script with a diagnosis on it, follow what the reason for the testing is, so if the script
notes “hernia”, then code the hernia followed by the Z11.59 for the screening. If the only reason is
Pre-admission testing – then code the Z01.818 followed by the Z11.59. Code your PAT encounters
the same as you would before COVID, and simply add the Z11.59 for the screening as a secondary
code.
5) If a patient has a COVID/SARS antigen test as an outpatient, no symptoms, what Z code is
recommended to use?
The antigen test is a diagnostic test for COVID, don’t confuse it with the antibody test. With that
being clarified, the Z20.828 should be assigned if the patient has a negative test, if the test is
positive then the U07.1 should be assigned.
6) When a previously positive covid patient is tested for discharge clearance and the results are
negative should we also code the screening test Z11.59?
In our experience, patients could be tested many times during an admission, depending on the
length of stay, it has not been our practice to assign a screening code during an inpatient stay.
Unless your facility codes screenings on inpatient encounter regularly, any testing during the
inpatient encounter would not be coded separately.
7) I have a question regarding the appropriate usage of Z11.59 versus Z20.828. When a patient
comes in for preadmission testing, we have been using Z11.59, but after your presentation
yesterday I thought I heard you indicate that we should be using Z20.828 as the pandemic had
been extended until October? Can you remind me who you said extended the Pandemic
timeframe? Do we not use Z11.59 during this time then at all as we are all considered to have
been exposed and then Z20.828 would be the only appropriate code?
The Z11.59 is for PAT work only. The Z20.828 would be used for every other situation where there
is not a positive result. That advice was communicated via the AHIMA Engage Board, with a
person posting the advice they got from Coding Clinic. In the presentation we stated that the
health emergency declaration from HHS – which encompasses all of the waivers – was extended for
90 days – which lands in October. Only the WHO can declare the pandemic over – and we are sure
that information will come from the WHO and CDC at the appropriate time. If Coding Clinic
publishes other advice as to the assignment of Z11.59, then of course follow the updated Coding
Clinic advice.
8) Could you address what to code for patients who present with other conditions, but facility
protocol is to issue a COVID test prior to any admission or surgery. Results are negative. For
asymptomatic patients presenting for outpatient lab, what dx. Code are you assigning for this.
If patients are being tested in the ED prior to an unscheduled admission and the results are
negative the Z20.828 should be assigned. If a patient is being screened prior to a scheduled
procedure and has no known exposure, then the Z11.59 should be assigned.
9) During the pandemic is it assumed that everyone has a possible exposure to COVID, and we
should use the Z20.828 for hospital admissions when they give a COVID test to everyone, and
never use the Z03.818? I am still confused.
Correct, the Z03.818 should not be used during the pandemic, assign only the Z20.828 and follow
Guideline I.C.21.c.1, in a pandemic everyone is assumed to be exposed.
10) If a patient tested positive while in acute care setting and is now in Skilled bed for debility and
has negative test, how would this be coded?
The coder needs to establish whether the patient has recovered from the COVID infection or
whether they are dealing with the residuals of a current infection. If the patient has recovered
then assign the Z86.19, if the patient is still dealing with the infection, the U07.1 should still be
assigned. Do not assign a history of COVID code based on a negative test.
11) Does the following mean that we can code directly from the positive lab result regardless of
what the provider documents or does the provider need to document the positive results?
Code only confirmed cases: Code only a confirmed diagnosis of the 2019 novel coronavirus disease
(COVID-19).asdocumented by the provider, documentation of a positive COVID-19 test result, or a
presumptive positive COVID-19 test result. For a confirmed diagnosis, assign code U07.1, COVID-19.
This is an exception to the hospital inpatient guideline Section II, H. In this context, “confirmation”
does not require documentation of the type of test performed; the provider’s documentation that the
individual has COVID-19 is sufficient.
Does the following only apply if the positive test results come back after discharge? We are unsure about
how to interpret the newly released COVID-19 guidelines in relation to the uncertain diagnosis guideline
which refers to diagnoses “documented at the time of discharge” stated as possible, probable, etc. Can we
code these cases as confirmed COVID-19 if the test results don’t come back until a few days later and the
patient has already been discharged? (4/1/2020) Yes, if a test is performed during the visit or
hospitalization, but results come back after discharge positive for COVID-19, then it should be coded as
confirmed COVID-19.
The answer here is yes, if a test result comes back positive, the coder will assign the U07.1 without
having the provider document positive results. The only documentation the coder needs is that a
test was done, if the results are negative, code the Z20.828.
12) If a test was ordered but no test was performed due to a problem in handling, do we still
assume exposure due to the pandemic or treat it as like no test.
Yes, assign the Z20.828. It is the same concept as an unsuccessful procedure, the specimen was
still taken, so it is no fault of the patient that the test did not get completed or produce a result.
13) What ICD-10-CM code would be recommended to be used for patients coming in requiring a
COVID test be done prior to air travel?
While this scenario seems similar to the PAT testing, the advice here would be to assign Z20.828 as
this testing is being done for possible exposure, rather than for screening for hospitalization. This
might be a good question to pose to Coding Clinic for further clarification.
14) We can code a positive Covid result without confirmation from provider? Can code from lab
result??
As stated in the coding guidelines for COVID-19 infections that went into effect on April 1, code
U07.1 may be assigned based on results of a positive test as well as when COVID19 is documented
by the provider. This is an exception to the rule about coding from test results and can only be
applied to COVID testing.
15) July 17, 2020 ICD10 Monitor put out an article talking about new guidelines that go in effec
t on Oct 1 2020 and that they advise that the use of the Z11.59 should be discontinued during the
pandemic and replaced with Z20.828. Your presentation stated to use the Z11.59 for pretesting.
Are you still suggesting we use the Z11.59 for pretesting? (the article can be found here:
https://www.icd10monitor.com/news-alert-fy-2021-icd-10-cm-guidelines-released-covid-19-coding-guidance-update)
The only advice we have seen from Coding Clinic and that was indirectly via the AHIMA Engage
Message Board was to assign the Z11.59 for PAT work only. Of course, if Coding Clinic publishes
different advice, our recommendation is always to follow the Official Coding Guidelines along with
the what is published by Coding Clinic at that time.
16) If a patient is admitted and going to a skilled nursing facility and has to be screened for covid
while they are here what diagnosis code should we be using?
17) What code is appropriate for coding an inpatient being screening for COVID before being
discharged to a nursing home, not the Z11,59? You would code the Z20.828?
This answer is for the two questions above, as they are similar. This could go many ways, it would
depend on the circumstances of the admission, if the patient was a COVID patient in the first place,
the COVID code whether it be U07.1 or Z20.828 would already be coded. If the COVID test has
nothing to do with the admission, then assign Z20.828 or U07.1 depending on the test results.
18) How to code a patient who had COVID last month was treated and is now asymptomatic BUT
still testing positive for COVID. Do we code the U or the Z code?
The positive test shows active infection, so it would be appropriate to assign the U07.1 here.
19) My question is, a patient confirmed with COVID-19 10 days before now in this particular
medical record, it is mentioned as patient is having signs and symptoms and not related to
COVID-19confirmed is documented in Medical Record. So, in this case can we take that as
suspected or confirmed COVID?
You have to be careful with the “suspected” here, remember only confirmed cases of COVID-19 can
be coded. If the patient is confirmed to have COVID 10 days prior, and the signs and symptoms
bringing the patient to the hospital are not COVID related, then the coder should query to see if the
patient still has an active COVID infection, or if the provider considers the COVID to be resolved. If
the patient still has active infection, the U07.1 should be assigned as a secondary diagnosis since it
was not the reason for admission, if the query response says resolved COVID, assign the Z86.19 for
history of COVID.
20) We have been coding Z03.818 for all testing w/o an order because we do not know if patient is
asymptomatic or not. You recommend using Z20.828 should we re-code the existing accounts
that have been already done? Also, we are a State Reporting Facility which as I understand we
don't need to require an order. Do you recommend that State Facilities also get orders if
possible?
I think AHIMA just put out a bulletin regarding using the Z20.828 for pre-op?????
If your facility or type of facility doesn’t require an order, then we don’t recommend getting an
order. As noted in the presentation, the Z03.818 is not appropriate for use in the pandemic, refer
back to the Guideline I.C.21.c.1, in a pandemic everyone is assumed to be exposed. As far as going
back and changing any coding, that would depend on your facility getting denials. If your claims are
being paid, then use the Z20.828 going forward and correct any denials. We have not seen
anything from AHIMA regarding the Z20.828 for pre-op, so if the person who posed this question
has a link to such advice, please forward it our way.
21) Do you suggest using Z01.818 with Z11.59 for the pre-op testing?
Only if you have an order or script that indicates pre-op testing, there are times that the order or
script indicates the reason for the procedure, so we have seen the reason for the surgery as the
first listed diagnosis.
22) Please clarify coding of "possible COVID” in the OP setting with a positive test result.
The positive test result indicates a COVID infection, so the coding of the U07.1 is the appropriate
code, but with the OP rules about possible diagnoses, the recommendation here would be to code
the U07.1 as the guideline indicates, but also attempt to get the documentation amended for
appropriateness. Another recommendation would be to have registration stop any “possible
COVID” diagnosis and get the documentation corrected on the front end.
23) A patient has tested positive in a different facility prior to admission to my facility. The
physician documents "patient positive for Covid-19, past 21-day window of being infectious". The
patient has acute respiratory failure or pneumonia. can I code the U07.1 if the physician does not
specifically link the covid-19 and the current illness or would I use the history code?
As long as the physician states that the patient has confirmed COVID, assign the U07.1, especially in
this instance, it is specific. The history code would be used when there is no longer any active
infection.
24) Screening Code for admission to admit to SNF from IRF? Code for patient that had a Positive DX. at another facility, recovered then has an IRF admission. can I code the U07.1 if the physician does not specifically link the covid-19 and the current illness or would I use the history code?
If the documentation supports that the patient has recovered from COVID-19, then the Z86.19 is
the appropriate code to assign here. If there are residuals, code those conditions. When in doubt
about whether or not the patient has recovered, query the physician.
25) If a patient comes in for lab work and the only lab test ordered is for covid testing and the
diagnosis is for supervision of pregnancy. How would this be coded?
If the patient is positive, assign O98.5- and the U07.1, if the patient is negative, assign the Z code
for the appropriate supervision of pregnancy code, and assign the Z20.828.
26) What E&M type charge should be used when the patients came for covid testing to the ER and were seen briefly in their car?
There would not be an E&M charge here, only the testing codes. Patients being seen for testing in
their cars, are not being evaluated as a patient would be in the ED, office, or clinic setting.
27) If you have covid pneumonia and COPD, do you code the COPD as w/ acute lower respiratory infection?
Yes, follow all appropriate guidelines and instructional notes whether or not the patient has a
COVID infection.
28) Can hospitals bill for CPT 99421-99423? The status indicator is listed as B. Is there a Medicare preferred (G-Code) to use instead or if not chargeable, is there a hospital equivalent code?
This question refers to E-visit codes. E-visits are a communication between a patient and their
provider through an on-line portal. The presentation did note that these codes are for use with
established patients, although in this time of COVID and waivers, new patients can be seen via the
E-visit technology. The codes are for use for the providers; therefore, the hospitals would not
assign these codes for facility billing. There is not an equivalent G code to equate to the 99421-
99423 codes, the G2061-G2063 are for use when qualified non-physician providers can bill for their
services. The status indicator of B means that this service is not paid when the bill type is 12x or
13x – which again are facility bill types.
29) Where was the announcement of the pandemic extension to Oct 23rd, 2020? Did not see this on the CMS website?
To clarify the health emergency declaration is from HHS – which encompasses all of the waivers. In
the presentation, it was noted that the declaration was extended for 90 days – which lands in
October. After looking for a link to share, we found that it is expected to be extended before it
expires on July 25th. On Monday, June 30, 2020, HHS spokesman Michael Caputo tweeted that HHS
intends to extend the COVID-19 public health emergency before it expires on July 25, 2020. Once extended,
the public health emergency will be effective for an additional 90 days. Extending the emergency declaration
will allow providers to continue to use waivers and flexibilities issued to assist them in responding to the
COVID-19 pandemic. Only the WHO (World Health Organization) can declare the pandemic over –
and we are sure that information will come from the WHO and CDC at the appropriate time.
30) How do we code the Antibody testing? How are positive for covid 19 antibodies results coded?
Negative results?
31) Do you code Z0184 as the principle dx, on an outpt lab, if the test is just listed as an antibody test and there is a listed dx?
This answer applies to the two questions above as they are similar: According to the AHA/AHIMA
published FAQ’s, for an encounter for antibody testing that is not being performed to confirm a
current COVID-19 infection, nor is being performed as a follow-up test after resolution of COVID19, assign Z01.84, Encounter for antibody response examination.
If this is an encounter for the testing, the Z01.84 is enough to code, remember the antibody testing
in most circumstances is not being done to confirm a current COVID-19 infection. The positive or
negative results are looking for the antibodies, not the infection.
32)Our facility is sometimes using the test 0202U (22 Target SARS-COV-2). Is this test covered by
Medicare the same as the 87635, 0001U, etc.? Do we apply the CS modifier on the E&M for this
as well?
The specific code 0202U is a PLA code or a Proprietary Lab Analysis Code. PLA codes are a way to
identify a specific lab or manufacturer, these codes are a way to more specifically identify their
testing as opposed to another lab or manufacturer. Many commercial payers require prior
authorization to assess whether medical indications for the procedure were followed by looking at
both the diagnosis and code. Also, note for Medicare, that PLA codes fall into the ABN
authorization, so unless you have a patient sign an ABN for a PLA test, you can’t charge the patient
for it. The CPT Assistant issues for May and June 2020 also have advice on the use of these codes.
The CS modifier should be appended to any service related to COVID-19 testing-related services.
33) Should the CS modifier be placed on testing for pre admission?
The CS modifier should be appended for services furnished on March 18, 2020, and through the
end of the PHE, use the CS modifier on applicable claim lines to identify the service as subject to
the cost-sharing wavier for COVID-19 testing-related services and to get 100% of the Medicareapproved amount:
Results in the deductible and coinsurance being waived
Services are medical visits for the E&M categories when an outpatient provider,
physician, or other providers and suppliers billing Medicare for Part B services orders or
administers COVID-19 lab test U0001, U0002, or 87635
The CS modifier does not apply to services unrelated to COVID-19.
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