Radiologists practicing in an imaging center or other non-hospital facility have a new tool available that will potentially allow them to recover some of the added costs related to safety precautions taken during the COVID-19 public health emergency. CPT code 99072 was added by the American Medical Association (AMA) Current Procedural Terminology (CPT®) Editorial Panel on September 8, 2020, with immediate effect. While payment for this code is not yet available from Medicare, it might be reimbursed by some commercial payers.
CPT 99072 is defined to include “Additional supplies, materials, and clinical staff time over and above those usually included in an office visit or other non-facility service(s), when performed during a Public Health Emergency as defined by law, due to respiratory-transmitted infectious disease.” The current COVID-19 public health emergency is declared for 90 days at a time and, as of this writing, it will expire on January 21, 2021 with the possibility of further extension. The code may be reported only once per in-person patient encounter per day regardless of the number of services rendered at the encounter.
The costs contemplated by this code must be over and above those usually included in a visit or service, and might include:
- Additional time spent by clinical staff to
- Conduct pre-visit screening of patients
- Provide instructions on social distancing during the visit
- Check patients for symptoms upon arrival
- Perform additional cleaning of the procedure room and imaging equipment
- Apply and remove personal protective equipment"
- Additional costs of
- Surgical masks not typically worn during an office visit or procedure
- Increased quantities of cleaning supplies such as hand sanitizer and disinfecting wipes, sprays and cleansers
While the code description specifies ‘clinical staff time’ in the performance of these tasks, the supplemental information provided by the AMA indicates that it is equally appropriate when performed by a physician or other qualified health care professional.
The fee to be billed with this code is best developed by looking at the actual cost of the services and supplies involved. This will require some research and analysis. For the cost of supplies, the purchase price of a certain quantity of items will have to be divided by the number of patients it will cover. The unit price of individual items like masks is easy to determine, so then you need to find out how many masks are used per patient visit. When a mask is issued to staff members once per day (or perhaps less often), how many patients are seen by the person using that mask in an average day? Similarly, a quantity of cleaning supplies will be used over a number of days, so the task is to determine how many patients that quantity services.
The time spent by staff performing the tasks listed above can be estimated by observing and recording the time for each task. How many patients can be called in an hour? How long does it take to check a patient for symptoms upon arrival? How long does it take from the time a patient leaves the exam room until it is ready for the next patient? Each of these tasks has to be evaluated to identify the extra time required over and above what was normally done before the public health emergency. Once the blocks of time are identified, the cost of the staff can be applied. In addition to the hourly rate paid, add a factor that covers payroll taxes and employee benefits.
In the absence of federal guidance from Medicare, the reimbursement results will be quite varied. Anecdotal reports indicate that some commercial payers are reimbursing practices for 99072, including:
- Some BCBS plans
The code might at first be rejected by claims clearinghouses, but over time they should begin to accept it – with no guarantee of payment!
There may be legal prohibitions against a practice billing for COVID-related costs. Practices that received funds from the Department of Health and Human Services (HHS) under the Provider Relief Fund distributions are precluded from collecting directly from patients; it is unclear if payment from an insurance plan is also prohibited. Certain states, such as New York and Virginia, prohibit practices from charging patients for personal protective equipment.
It is recommended that imaging consultation reports include some documentation of the need for billing CPT 99072. Guidance from the AMA states, “Documentation requirements may vary among third-party payers and insurers; therefore, they should be contacted to determine their specifications.” Language such as, “During the COVID-19 Public Health Emergency we are taking all necessary precautions to safely provide medical services to our patients, including the use of personal protective equipment and increased sanitation measures to prevent the spread of communicable diseases.” could be included in each report.
The decision to submit claims under CPT 99072 or not, along with the amount to be submitted, is one that each practice will have to make on its own. There is no clear guidance available to date. We will continue to monitor this topic and keep our blog readers informed. Subscribe today to get the latest article delivered straight to your inbox.