Can I Get Paid for All the Extra Time and Money COVID is Costing Me?
The worldwide effect of the coronavirus disease (COVID-19) is unprecedented and multidimensional. Some providers and staff who have been to their Medical Doctor or Dentist in the past few months have experienced a small charge added onto their services. It’s meant to offset the costs of extra sanitizing, personal protective equipment (PPE), and time spent during this Public Health Emergency (PHE).
The American Medical Association (AMA) Current Procedural Terminology (CPT ®) Editorial Panel is tasked with ensuring that CPT codes remain up to date and reflect the latest medical care available to patients. To achieve this, the CPT Editorial Panel has set a precedent for rapidly releasing CPT codes during the pandemic to address this emergent issue.
In keeping with this practice, the CPT Editorial Panel approved two new Category I codes and expedited the publication of these new codes to the AMA website on Tuesday, September 8, 2020. One such code addresses the issue of extra expense for the additional cost burden for providers in this exceptional time.
There Is A Code
As quoted in the AMA’s CPT Assistant:
|“New code 99072 represents a new practice expense code specifically intended for use during a declared PHE as defined by law, due to respiratory-mitted infectious disease. It accounts for additional supplies, materials, and clinical staff time required for patient symptom checks over the phone and upon arrival, donning and removing personal protective equipment (PPE), and increased sanitation measures to prevent the spread of communicable disease. This new code is established in response to the significant additional practice expenses related to activities required to safely provide medical services to patients in person during a PHE over and above those usually included in a medical visit or service. This new code should only be reported when the service is rendered in a non-facility place of service (POS) setting, and in an area where it is required to mitigate the transmission of the respiratory disease for which the PHE was declared.”|
But What About Chiropractic Practices?
We’ve done the research on this code and our team of certified specialists has agreed on the following for our members which we hope can help you make decisions for you and your office. Because the code is directly associated with increased expenses for the office due to COVID-19, we recognize that some offices may be more impacted than others and have a greater need for offsetting the additional costs incurred. Most of our members have clarified that their increased costs have leveled out and they feel there isn’t an ongoing, increased expense to the clinic at this point. However, we recognize that as we come into the Fall and Winter months, things could ramp up and we could see another serious outbreak in our areas.
Our team collectively believes that all providers and billing team members should be aware of this new code and its availability. Those of us who have been around a long time may remember CPT code 99070, typically reported for supplies and materials that may be used or provided to patients during an office visit or other service(s) provided in the office setting. However, the newly established code differs significantly. First, new code 99072 is reported only during a PHE and only for additional items required to support a safe in-person provision of evaluation, treatment, or procedural service(s). These items contrast with those typically reported with code 99070 which focuses on additional supplies provided over and above those usually included with a specific service.
The Reality and Hard Facts
Some DC’s may see this new code as an opportunity to either recover expenses or simply increase revenue. We don’t foresee this being paid by Medicare, or many other payers, which would leave the patient liable for the expense. Because we could not charge one class of patients and not another, most would bear this expense out of pocket. In an office that sees 150 patients per week, charging $10 for this code would result in a revenue increase of $1500 per week. Because the charges should be based on the approximate expense to the practice, it may be difficult to justify $1500 in increased expenses based on cleaning supplies, time to complete these services, etc. Multi-disciplinary practices may have providers who perform more invasive procedures or treat other respiratory issues, and therefore, may require additional sanitation of equipment and rooms.
Who Qualifies as “Clinical Staff”?
The state scope of practice laws and regulations will help determine who is considered clinical staff and who is considered another qualified healthcare professional. The AMA CPT Assistance from March 2020 defines a clinical staff member as “a person who works under the supervision of a physician or other qualified health care professional and who is allowed by law, regulation and facility policy to perform or assist in the performance of a specified professional service, but does not individually report that professional service.”
As of now, our research has not revealed any guidance from individual payers, other than finding Anthem Medicaid in KY doesn’t require pre-authorization. We believe this will be a very fluid code and is at the mercy of some states and most payers. Here’s our best advice:
- The time counted in any other time-based visit or service during the same encounter cannot be counted twice to report this code.
- Verify who is classified as clinical staff according to your state and individual payers.
- When reporting 99072, report only once per in-person patient encounter per day regardless of the number of services rendered at that encounter.
- There is no specific ICD-10 code required for the use of 99072.
- If a payer wants you to report a code outside of its intention, make sure to get it in WRITING!
- Be aware that this code is out there and available to you; carefully consider whether an additional charge for the extra costs is right for your practice.
- If you elect to make this charge to patients, you should notify them at the time of scheduling, and notify those already scheduled of the increased cost. You might decide to waive it until their next visit.
- Reach out to your individual payers for additional guidance and to find out whether the charge is reimbursable when billed to insurance. If you are contracted with a payer, ensure that you are allowed to charge the patient upfront, with a signed waiver. Make sure you get that waiver signed before collecting directly.
- If you can’t get clear guidance from a contracted payer, consider billing the code and watching for the adjudication from the payer. Be sure you have a signed waiver from the patient first that if it isn’t paid, they will cover the cost.
- Remember, billing any code has the potential for a post-payment audit. If you are charging based on your actual costs, keep a solid record of your increases in costs for supplies and time to present should there be a question.
We hope this additional information helps with your decision making about the use of this code. Please feel free to reach out to our specialists for guidance about your individual situation. Click here to review the AMA’s CPT Assistant guidance.
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