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Resolved CPT 99072

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99072 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.

CPT® Assistant provides guidance for new codes
CPT Assistant is providing fact sheets for coding guidance for new SARS-CoV-2 (COVID-19)-related testing codes.

The fact sheets include:
  • Codes, descriptors and purpose
  • Clinical examples
  • Description of the procedures
  • FAQs

Question: For what type of patient encounters or services should code 99072 be reported?

Answer: Code 99072 may be reported with an in-person patient encounter for an office visit or other non-facility service, in which the implemented guidelines related to mitigating the transmission of the respiratory disease for which the PHE was declared are required. Use of this code is not dependent on a specific patient diagnosis. For a list of POS codes with facility/non-facility designations that are available in the Medicare Claims Processing Manual, visit https://www.cms.gov/Medicare/Coding/ place-of-service-codes.

Question: What documentation is required to report code 99072?

Answer: Given that code 99072 may only be reported during a PHE, one would not report this code in conjunction with an evaluation and management (E/M) service or procedure when a PHE is not in effect. Therefore, code 99072 is reported justifiably only when health and safety conditions applicable to a PHE require the type of supplies and additional clinical staff time explained in the code descriptor. Documentation requirements may vary among third-party payers and insurers; therefore, they should be contacted to determine their specifications. Question: May code 99072 be reported with code 99070? Answer: Yes, code 99072 may be reported with code 99070 when the requirements for both codes have been met. Note that eligibility for payment, as well as coverage policy, is determined by each individual insurer or third-party payer.


 
new CPT code 99072 which is only valid during a PHE:

The AMA CPT® Assistant on the new codes can be found at:
https://www.ama-assn.org/system/files/2020-09/cpt-assistant-guide-coronavirus-september-2020.pdf

It says about 99072:

New code 99072 represents a new practice expense
code specifically intended for use during a declared
PHE as defined by law, due to respiratory-trans- 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. A comprehensive
list of POS codes and their facility/non-facility designations
are found in the Medicare Claims Processing
Manual at https://www.cms.gov/Medicare/Coding/
place-of-service-codes.
Users familiar with the CPT code set will recall
that code 99070 is 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,
such as drugs, intravenous (IV) catheters, or trays.
Secondly, the new code is also intended to account
for the additional time required by clinical staff to
provide the service safely.
This new code is designed to capture the following
practice expense factors such as:

• Time over what is included in the primary service
of clinical staff time (registered nurse [RN]/
licensed practical nurse [LPN]/ medical technical
assistant [MTA]) to conduct a pre-visit phone call
to screen the patient (symptom check), provide
instructions on social distancing during the visit,
check patients for symptoms upon arrival, apply
and remove PPE, and perform additional cleaning
of the examination/procedure/imaging rooms,
equipment, and supplies

• Three surgical masks

• Cleaning supplies, including additional quantities
of hand sanitizer and disinfecting wipes, sprays,
and cleansers

To further delineate the use of code 99072, a parenthetical
note has been added to code 99070 directing
users to the new code when the additional supplies,
materials, and preparation time meeting its criteria
are utilized.

Code 99072 is to be reported only once per in-person
patient encounter per provider identification number
(PIN), regardless of the number of services rendered
at that encounter. In the instance in which the noted
clinical staff activities are performed by a physician
or other qualified health care professional (eg,
in practice environments without clinical staff or a
shortage of available staff), the activity requirements
of this code would be considered as having been met;
however, the time spent should not be counted in any
other time-based visit or service reported during the
same encounter.

The following clinical examples and procedural
descriptions reflect typical clinical scenarios for which
it would be appropriate to report these new codes.

99072
A 65-year-old female presents to the physician’s
office, requiring care for an illness, acute injury, or ongoing care for a chronic condition. The encounter
occurs during a Public Health Emergency (PHE), as
defined by law, due to respiratory-transmitted infectious
disease.
Description of Procedure
(99072)

Question: Code 99072 is stated as being applicable
“during a PHE.” What information should be used to
verify when a PHE is in effect?
Answer: A PHE is in effect when declared by law
by the officially designated relevant public health
authority(ies).

Question: For what type of patient encounters or
services should code 99072 be reported?
Answer: Code 99072 may be reported with an
in-person patient encounter for an office visit or
other non-facility service, in which the implemented
guidelines related to mitigating the transmission
of the respiratory disease for which the PHE was
declared are required. Use of this code is not dependent
on a specific patient diagnosis. For a list of POS
codes with facility/non-facility designations that
are available in the Medicare Claims Processing
Manual, visit https://www.cms.gov/Medicare/Coding/
place-of-service-codes.

Question: What documentation is required to report
code 99072?
Answer: Given that code 99072 may only be
reported during a PHE, one would not report this
code in conjunction with an evaluation and management
(E/M) service or procedure when a PHE
is not in effect. Therefore, code 99072 is reported
justifiably only when health and safety conditions
applicable to a PHE require the type of supplies
and additional clinical staff time explained in the
code descriptor. Documentation requirements may
vary among third-party payers and insurers; therefore,
they should be contacted to determine their
specifications.

Question: May code 99072 be reported with code
99070?
Answer: Yes, code 99072 may be reported with code
99070 when the requirements for both codes have
been met. Note that eligibility for payment, as well
as coverage policy, is determined by each individual
insurer or third-party payer.

9/14/20 update
I just was asked a few questions about the new CPT code 99072 which can only be used during a Public Health Emergency (PHE). They wanted to know what I felt the documentation should be and if a modifier is needed when coded with an EM service. Here is how I responded to the doctor:
The only guidance we have is from the AMA CPT® Assistant that I sent you. From reading it, it does not indicate what is required for documentation. It is not an add on code, but it is billed with an E&M code. I do not see a reason for a modifier, but we do not know how payers are going to treat the code.
For dictation, I recommend you put what the standard cleaning that is required between patients due to COVID-19 and what the PHE that is required for each patient with your templates/compliance manual. Then in the dictation for each patient the provider can say:
And if audited, you have to remember to pull the standard cleaning protocol and PPE requirements and include it with the note.
There is a chance (rather a good chance) that payers will not be paying for this code. But I feel doctors have to keep billing it, even if it gets written off on the back end, because if it is never billed, it will never get paid. The payers have to see the pricing and frequency of use, even if they are not paying it. Then when writing it off, have a special write off code, for “PHE Supplies not paid” or something like that so that you can track what this is costing you.

Courtesy of Barb Cobuzzi
 
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