COVID-19 Timeline and Coding and Reimbursement Challenges

Submitted by: Lesly Carreras, RHIA, CCS
FHIMA President-Elect

Last year at this time we could not have begun to imagine the changes and financial impact COVID-19 would have in our places of work. The media began to report the first few COVID-19 cases in the United States and bring forth images of the devastation coming our way. The images from China, Italy, and all of Europe were extremely worrisome.

On February 29, 2020 state labs in Tampa, Jacksonville, and Miami gained the capability to process COVID-19 tests; previously only the federal labs were able to process these tests. On March 1, 2020, our Governor, Ron DeSantis, announced that the first two Floridians have tested positive for COVID-19, a 29-year-old woman from Hillsborough County who had recently returned from Italy, and a 63-year-old man from Manatee County who had come in contact with someone who had tested positive. A few days later, the Florida Department of Health issues guidelines to stop the spread of COVID-19 asking residents not to travel overseas.

After a few more incidents, DeSantis declares a state of emergency to create a pathway to obtain funding and resources to stop the spread of COVID-19. On March 11, 2020, the CDC declared Coronavirus a pandemic. Then the toughest news for South Floridians came on March 24, 2020 -- the stay-at-home orders were issued for parts of Miami-Dade, Alachua, and Orange County. About half of the states reported COVID-19 cases were in Miami-Dade, Broward, and Palm Beach counties; there were 1,467 cases in Florida at that time.

As everyone was scrambling to stay safe and gather supplies from our stores, which could not keep up with the demand, our Emergency Room and hospitals doors remained open. We began to formulate our plans for the next couple of weeks; yet that later turned to months, and a year later here we are. 

On March 18, 2020, the World Health Organization put out the emergency code U07.1, COVID-19, to be used for confirmed cases after April 1, 2020. Since then, we have had multiple updates with additional ICD-10 CM diagnosis codes and ICD-10-PCS codes related to treatment for the virus, along with many more CPT procedure and HCPCS codes for laboratory tests and vaccines.

Telemedicine took the front seat. In a matter of days, our outpatient visits turned to virtual encounters. Our hospitals and clinics scrambled to develop new policies and procedures on how to document and bill for these new services. Extensive calls with our payers to establish a claim submittal and reimbursement workflow was of utmost importance.

To deal with the “new kid in town”, Telehealth, virtual meetings, and daily huddles flooded our calendars as we deciphered with our coding staff the new coding workflows and updates. We created a grid for our outpatient coders with our payers Telehealth guidelines for coding and reimbursement (see links for resources below). For our inpatient coding team, the challenge was showing our clinicians how to document when they were busy treating our very sick patients.

Moving forward the focus is to be ready for anything. As your staff moves to working offsite, ensure a good sound Telecommuting Policy is available. If you do not have one, draft a policy that addresses PHI protocols, remote connectivity, equipment, work schedule, and work expectations. Fortunately for many of the HIM Departments out there, we had experience with staff working remotely. This new concept was new to many hospital departments that did not have policies or the processes in place to make this a smooth transition, and they reached out to HIM for guidance. 

As we begin 2021, we are still facing many of the same challenges of 2020, but we are hopeful that with the COVID-19 vaccine a cure is on the horizon. The HIM Professionals have once again stepped up to the occasion and demonstrated we are resourceful bunch, and we are here for the long haul.

 It is very important to stay “In the Know”. Bookmark AHIMA’s COVID-19 Resources:

• Journal of AHIMA—COVID-19. An authoritative source for healthcare-relevant news and perspectives on the global response to the COVID-19 pandemic. Click here.
  
• AHIMA.org COVID-19 Index. Continuously updated with resources, AHIMA news, and navigable links to public health and professional organizations. Click here.

The January 2021 ICD-10-CM Addenda and updated ICD-10-CM Official Guidelines for Coding and Reporting are available at:  https://www.cdc.gov/nchs/icd/icd10cm.htm.

Additional References:

• Medicare Telemedicine Health Care Provider Fact Sheet
• HHS: Notification of Enforcement Discretion for telehealth remote communications during the COVID-19 nationwide public health emergency
• HHS Limited Waiver of HIPAA Sanctions and Penalties During a Nationwide public Health Emergency
• HHS: Waiver or Modification of Requirements under Section 1135 of the Social Security Act as the Result of the Consequences of the 2019 Novel Coronavirus (COVID-19)
• HHS BULLETIN: Civil Rights and the Coronavirus Disease 2019 (COVID-19)
• CMS: MLN Booklet – Telehealth Services
• HHS: Defending Against COVID-19 Cyber Scams
• CMS Medicare Claims Processing Manual – Telehealth included
• Center for Connected Health Policy
• SAMHSA COVID-19 Public Health Emergency Response and 42 CFR Part 2 Guidance
• Health IT.gov: Your Health Information Security
• Health IT.gov: What is a ‘Secure Wi-Fi Network’?
• CMS Announces Relief for Clinicians, Providers, Hospitals and Facilities Participating in Quality Reporting Programs in Response to COVID-19
• American Medical Association quick guide to telemedicine in practice