Friday, March 6, 2020

CMS Announces Special New Codes for Coronavirus Testing

On March 13, CMS announced national pricing for COVID at $36 for the CDC kit test (which doesn't require internal development and might even start with a free CDC kit - not positive) and $51 for the local LDT test of various types.  PDF here.   

This is comparable to my forecast March 1, when I noted the general price for multiplex viral pathogen is $43.    To avoid federal rulemaking, CMS lists the price in the above PDF as being a reflection of the price that was set by each individual contractor (MAC).


CMS has announced two special codes for Coronavirus testing, both effective April 1, 2020.   U0001 will represent CDC-kit testing, and U0002 will represent other testing.

See the March 5, 2020 CMS press release here:

"CMS developed the first HCPCS code (U0001) to bill for tests and track new cases of the virus. This code is used specifically for CDC testing laboratories to test patients for SARS-CoV-2. The second HCPCS billing code (U0002) announced today allows laboratories to bill for non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19)."

In transmittals on the Clin Lab Fee Schedule here and outpatient fee schedule here:

Code: U0001
Short Descriptor: 2019 –nCoV diagnostic P
Long Descriptor: CDC 2019 Novel Coronavirus (2019-nCoV) Real-Time RT-PCR Diagnostic Panel

Code: U0002
Short Descriptor: COVID-19 lab test non-CDC
Long Descriptor: 2019-nCoV Coronavirus, SARS-CoV-2/2019-nCoV (COVID-19), any technique, multiple types or subtypes (includes all targets), non-CDC

Codes Not Priced

CMS adds, "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. Laboratories may seek guidance from their MAC on payment for these tests prior to billing for them."

Medicare MACs will simply set a price they pay, reagardless of the inbound charge.  Options may include Options include 87797 (direct probe, per organism), 87798 (amplified probe, per organism), and 87799 (quantitative DNA/RNA probe, per organism.)  CMS pays $30, $35, and $43 respectively.


The codes can be billed retroactive to February 4, but do not submit the claim until April 1 or later.

Hospital Outpatient Bundling?

In general, virology tests are "bundled" in the ER or hospital clinic outpatient setting

In Transmittal T4544, CR11691, CMS states that the new U-codes for coronavirus are NOT BUNDLED but are PAID SEPARATELY (status "A").   This is an exception to the usually bundling of hospital outpatient chemistry and virology codes.   (Actually, if you look at outpatient virology codes/pathogen codes, most molecular ones are bundled "Q4" but very erratically and scattershot, some are "A" not bundled.  That's a topic for another day.)

Would CPT Panel Codes Override Special U Codes?  And Re-trigger Bundling?

I don't think CMS has addressed whether coronavirus on the same day as several other molecular viruses triggers the multi layer Respiratory Panel code set (which starts at n=3), which are ER- and clinic-bundled (Q4) and paid at fixed rates.   I suspect CMS wants coronavirus coded separately, but it's not in print.  Those panels do allow for DNA and RNA viruses and do mention coronavirus in parentheticals; recall it's also a long-familiar regular cold virus.   These are 3-5 respiratory viruses, any combo (87631 $142), (98632, 5-11 $128), (87633, 12+ $417).  These apply when multiplex probe techniques are used and while technically COVID assays are. well, multiplex, it's unlikely the whole set of a half dozen or more pathogens are "one multiplex" at this point.

CDC Issues ICD-10 Coding

CDC issued a news release March 5 on Coronavirus COVID-19 coding.  Frankly, it's exactly what I think any coding expert would come up with.  There is a code for coronavirus with another disease classification (B97.29).   This is the usual correct coding, J12.89 viral pneumonia + B97.29, a coronavirus.    CDC says do not use B34.2, coronavirus infection unspecificed, since you know it's respiratory, not unspecified.   See press release at CDC here.