By Catherine O’Leary, RN, managing director, healthcare advisory/CDI, KPMG.
COVID-19 is imposing a humanitarian and economic toll around the world, and healthcare providers are on the front lines of the response. New COVID-19 medical codes that went into effect on April 1 have an important part in clinical decision making, disease surveillance, population health management and research on the pandemic.
The new codes allow healthcare officials, clinicians, and researchers to capture claims data and use the information to better inform a course of action tied to COVID-19, whether that is for setting aside more beds, creating special units to handle the highly contagious viral infection, routing ambulances to facilities that can handle the emergency or other responses.
Because of the evolving situation, codes are rapidly changing. With every coding update, it is vital for everyone involved in the reporting of claims data, such as coding professionals, clinical documentation improvement specialists, healthcare IT professionals and coding auditors to respond to the changes.
All COVID-19 confirmed cases, documentation of a positive COVID-19 result, or a presumptive positive COVID-19 test result should be coded as U07.1, COVID-19. As a general rule, it is still imperative to follow the Official Coding Guidelines in the selection of principal or first-listed diagnosis (i.e., sepsis, obstetrics, etc.). Furthermore, it is important to report the other conditions/co-morbidities to present the overall severity and risk of mortality of a patient. If a patient presents with signs and symptoms with no definitive diagnosis, there are codes available to capture the reason for the encounter.
For patient discharges prior to April 1, providers should use the supplemental ICD-10-CM coding guidance for reporting cases related to COVID-19.
The tables accompanying this post outline some of the signs and symptoms, as well as codes for a diagnosis, related to COVID-19.
Telehealth guidance and COVID-19 coding
We are getting a lot of questions tied to telehealth, especially since the Coronavirus Aid, Relief, and Economic Security (CARES) Act, health plans, and Centers for Medicare & Medicaid eased several of restrictions.
This is the guidance that we’re receiving on telehealth:
- Services provided do not need to be COVID-19 related and can be offered in all settings, including a patient’s home.
- Payers will not enforce the requirement that patients will have an existing relationship with the physician (clinician?) providing telehealth.
- Physicians in one state may provide services to patients in another state, but state licensure applies.
- Providers will be reimbursed at the same rates as if the service was provided in person.
- Telehealth claims should properly reflect the place of service code (02-Telehealth).
With the coding guidance from CDC, the onus is still on healthcare providers to stay informed about the current regulations, as well as potential changes to ensure that COVID-19 encounters are recorded appropriately. Also, the data gathering helps with clinical decision making for quality patient care, disease surveillance, population health management, research and regulatory mandates.
As with many matters tied to healthcare, there is financial element that relates to billing and proper coding. The CARES Act provides $130 billion to support healthcare providers to prepare for and respond to COVID-19.
Healthcare companies, however, need to keep in mind a few things:
- Codes can be updated. It is important to stay current to make sure that cases are getting paid for and patients are getting tracked to help contain COVID-19 with an eye on developing treatments, a vaccine or implementing more public health measures such as continued social distancing.
- With any record being coded, sequencing guidelines should be followed. Many patients have much more nuanced cases in how they will present COVID-19, but you should have a position that you can defend the choices made if there is an audit.
- As a healthcare provider, it is incumbent to maintain data integrity and follow the guidance. While there is an easing of oversight tied to managing a crisis, there is nothing that prevents a regulator from coming back to a provider in a few years to challenge how certain codes were implemented and that agency – most likely CMS – may seek to recoup some of their spending.
Healthcare providers are facing the biggest public health crisis in a century with COVID-19. The tasks of data gathering and reporting may not be top of mind in the midst of equipment shortages and overflowing hospitals. However, coding COVID-19 cases the right way can help hospitals run better and empower clinicians and public health officials to make better decisions to overcome this pandemic.