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Anesthesia Coding Alert


Double Check CMS Guidance Before Submitting COVID-19 Claims

Ever-changing policies make updates more important.

As the coronavirus pandemic continues to affect the nation, medical providers in all specialties are continuing to be pushed to their limits. And policy makers are as well, as they attempt to keep abreast the ever-evolving situation. But take heart: Recent updates do offer more relief.

Background: On April 30, the Centers for Medicare & Medicaid Services (CMS) announced another round of “sweeping changes” to address the COVID-19 public health emergency (PHE) and its impact on the healthcare industry. A second interim final rule, published in the Federal Register on May 8, aims to offer regulatory flexibilities and advice as the nation moves into a new phase of the pandemic.

“The war is far from over, but in various areas of the country the tide is turning in our favor,” said CMS Administrator Seema Verma in a release. “Building on what was already extraordinary, unprecedented relief for the American healthcare system, CMS is seeking to capitalize on our gains by helping to safely reopen the American healthcare system.”

Pocket This Checklist of the Top Changes

CMS’ new waivers, expansions, and policy changes offer relief across a spectrum of healthcare mediums. Here’s a quick look at seven of the most important updates:

1. Telehealth: Among several telehealth updates, these are the standouts.

  • CMS will now allow more practitioners to bill for telehealth services, including physical therapists, occupational therapists, and speech language pathologists.
  • Certain telehealth E/M services can be audio-only now — with restrictions.
  • CMS is increasing some telehealth services payments to align with in-person visits.
  • The agency will use a subregulatory process during the PHE to add more telehealth services to its coverage list.

2. Testing: CMS hopes to up its COVID-19 testing ante and offers a plethora of pro-testing policies to back that up. Highlights include:

  • Any healthcare provider authorized under state law can now order COVID-19 testing for a beneficiary without a physician or nonphysician practitioner (NPP) written order.
  • Pharmacists acting as Medicare labs and within state law can administer COVID-19 tests.
  • Hospitals and providers who collect specimens for COVID-19 testing will get a separate payment.
  • NPPs like physician assistants (PAs), nurse practitioners (NPs), clinical nurse specialists  (CNSs), and others “may order, furnish directly, and supervise the performance of diagnostic tests” through the duration of the PHE, the interim final rule says.

Additional testing will continue even as cases drop, including those that test for COVID-10 antibodies.

“Antibody testing that identifies patients that have been exposed to the novel coronavirus (SARS-CoV-2) and developed an immune response is likely to have important public health implications by providing a clearer picture of the prevalence of the disease in the US,” stated AMA President Patrice A. Harris, MD, MA, in a news release about the new antibody test codes 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))

3. Hospitals and locations: With its “Hospitals Without Walls” initiative, CMS offers several new options to increase capacity and cover alternative venues for patient care. Examples of policy expansions include:

  • Allow teaching hospitals to add temporary beds.
  • Permit inpatient rehabilitation facilities (IRFs) to take in acute-care hospital patients.
  • Enable payments for some outpatient services in expansion locations like parking lots, gyms, and such.

4. Home health: Under the CARES Act, PAs, NPs, and CNSs can now offer home health services, including ordering care, establishing a plan of care, and certifying patient eligibility, indicates a CMS fact sheet.

5. Mental health: “Community Mental Health Centers can furnish certain therapy and counseling services in a client’s home to ensure access to necessary services and maintain continuity of care,” the fact sheet notes.

6. Staffing: CMS is easing up on the regulatory burdens associated with staffing. These workforce flexibilities are OK during the PHE:

  • Physical and occupational therapy assistants can do maintenance therapy to free up physical and occupational therapists for more important beneficiary services.
  • Residents at teaching hospitals can go to hospitals strained by COVID-19 without penalties.
  • Medical staff reappraisals at ambulatory surgery centers are waived under the PHE to allow clinicians to continue to assist patients without the administrative burden.

7. Skilled nursing facilities: Due to the vulnerability of skilled nursing facility (SNF) beneficiaries, CMS has released extensive guidance on the best way to help these patients as the country reopens. Policies include better infection controls and testing, stronger and quicker delivery of care, and “identification and mitigation of COVID-19 transmission,” the fact sheet stresses. The agency also added an SNF toolkit to its resources on May 13.

Plus: In addition, the administration announced the formation of a SNF-focused “Commission” to improve standards and thwart the spread of the coronavirus in nursing homes. The group is expected to start work in June and submit a collaborative report to CMS with policy ideas by Sept. 1, 2020.

Comments: If you’d like to add your input on the interim final rule, you can do so until July 7.

Resources: Review the interim final rule, including instructions on how to comment, at

See the CMS fact sheet from April 30 at