Pediatric Coding Alert

The ruling further stipulates that:

1. “U0003 should identify tests that would otherwise be identified by CPT^® code 87635 but [are] being performed with these high throughput technologies.

2. “U0004 should identify tests that would otherwise be identified by U0002 but [are] being performed with these high throughput technologies.

3. “Neither U0003 nor U0004 should be used for tests that detect COVID-19 antibodies.”

(Source: www.cms.gov/files/document/cms-2020-01-r.pdf).

The American Medical Association (AMA) has also established two new codes for antibody testing: 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])) and 86769 (Antibody; severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19])).

In their announcement, the AMA went on to note that these blood tests were for single-step (86328) and multiple-step (86769) methods; that 86328 is “appropriate for a point-of-care platform”; and that both codes were effective as of the date of the announcement — April 10, 2020 (Source: www.ama-assn.org/press-center/press-releases/ama-announces-expedited-updates-cpt-covid-19-antibody-tests).

Modifier alert: For Clinical Laboratory Improvement Amendments (CLIA)-certified labs, Medicare is requiring the QW (CLIA waived test) modifier be appended to U0002 and 87635 “for claims … with dates of service on or after March 20, 2020” (Source: https://www.cms.gov/files/document/r10066OTN.pdf).

Other Guideline Changes

CMS also released a new set of blanket waivers for healthcare providers during the public health emergency (PHE) on April 29, 2020. Many of the waivers affect facilities such as hospitals, critical access hospitals (CAHs) and long-term care hospitals (LTCHs). However, two telehealth waivers may possibly affect pediatric practices:

1) Requirements regarding the types of practitioners who may furnish services “as Medicare telehealth services from the distant site” are currently waived, and for the duration of the PHE, “any healthcare professional that is eligible to bill Medicare for their professional services” may do so.

2) Some telehealth services that require “interactive telecommunications systems” (i.e., that require video) may now be furnished using “audio-only equipment … for audio-only telephone evaluation and management services, and behavioral health counseling and educational services.” To determine which services may now be furnished this way, download the updated Covered Telehealth Services for PHE for the COVID-19 pandemic zip file at www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes and view the column labeled “Can Audio-only Interaction Meet the Requirements?”

For the complete updated CMS PHE waivers, go to www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf. The changes have a retroactive effective date of March 1, 2020 and are effective until the end of the PHE. And, as always, while the information in this newsletter is accurate as of the time of publication, remember to consult reputable sources such as CMS and AMA to stay on top of current developments during the emergency.