COVID Coding: Modifiers CR and CS and New ICD-10CM, HCPCS and CPT Codes

April 2020

The COVID crisis has drawn attention to some existing but little used modifiers.  It has also fast tracked some ICD-10-CM, Healthcare Common Procedure Coding System (HCPCS) and CPT codes. Because there have been some questions about need to use the modifiers, this article will address them first and then look at the new codes.

Modifiers CR and CS

Anesthesia, Pain Medicine and Critical Care practices frequently refer to Chapter 12: Physician/Nonphysician Practitioners in the Medicare Claims Processing Manual.  Recently, information found in Chapter 38: Emergency Preparedness Fee-for Service Guidance has taken on a heightened level of interest. 

CR Modifier

The CR modifier is to be used when Medicare payment for a service is dependent on whether CMS has issued a waiver.  Of note, CMS has instructed that the CR modifier is not to be used on claims for services newly added to its list of services that may be provided via telehealth.  

CS Modifier

Under the Public Health Emergency (PHE) patients will not be held responsible for deductibles, co-insurance or copayments for certain services they receive as part of their care for COVID.  This situation was last in effect during the 2010 gulf oil spill when CMS created this HCPCS modifier.  CMS is repurposing the CS modifier for some COVID care.  At present such care includes COVID testing and the encounter with a healthcare professional that led to the testing.  Effective March 18, 2020 and for the duration of the PHE, modifier CS should be appended to the codes that describe such services on claim forms so 100% of the allowed amount is issued to the provider and there is no patient responsibility for a remaining balance of the allowed amount.  

For additional information, please see https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c38.pdf

ICD-10-CM Code

A new diagnosis code was created and in an unprecedented move, the ICD-10-CM Coordination and Maintenance Committee implemented it mid-cycle rather than the usual method of making new ICD-10-CM codes effective on October 1 of each year. This code should be used as the primary diagnosis on claims; codes for any other disease manifestations should be reported as secondary diagnoses.

For additional information, please see https://www.cdc.gov/nchs/data/icd/COVID-19-guidelines-final.pdf

HCPCS Codes

The HCPCS code set, which is maintained by the Centers for Medicare & Medicaid Services (CMS) now includes two codes for testing for COVID-19.  The first code is used for the CDC test and the second for non-CDC tests. 

For additional information, please see https://www.cms.gov/newsroom/press-releases/cms-develops-additional-code-coronavirus-lab-tests

CPT Codes

The AMA’s CPT Editorial Panel has responded to the COVID pandemic by holding specially convened virtual meetings to establish new codes for testing for the disease and for testing for the presence of antibodies to the disease. 

For additional information, please see https://www.ama-assn.org/system/files/2020-04/coronavirus-long-descriptors.pdf

In addition to serving as an important payment tool, coding as a part of health information management holds a vital role in public health efforts to track, prevent and treat illness and injury.