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ACEP COVID-19 Field Guide

Table of Contents

Billing and Coding for COVID Care

Financial Guidance and Information

Payment for COVID-19 care

Medicare and Medicaid

For in-person evaluation and management (E/M) services conducted in the emergency department, emergency physicians can use the five emergency department E/M codes (CPT codes 99281-99825). Medicare and Medicaid are covering emergency telehealth services. Reimbursement of telehealth in Medicaid varies by state. For Medicare, the following is the official guidance:

  • Emergency physicians can perform telehealth services from any location, including the emergency department. CMS added the emergency department E/M codes (CPT codes 99281-99285), critical care codes (CPT codes 99291 and 99292), and observation codes (CPT codes 99217-99220, 99224-99226, and 99234-99236) to the list of approved Medicare telehealth services for the duration of the COVID-19 national emergency. The place of service code for emergency telehealth services is the same as what would be used if the services were delivered in person (for the emergency department codes, the place of service is 23). They should include modifier 95 with each claim.

Coverage of COVID-19 care

Testing

H.R. 6201, the Families First Coronavirus Response Act signed by President Trump on March 18, made testing for COVID-19 universally free (no cost-sharing) for most Americans, even those who are uninsured.

Clinical care

While testing is free, some insurers may not be waiving cost-sharing requirements for all treatment services of COVID-19 (eg, emergency department stays, hospitalizations). See ACEP’s summation of the latest COVID-19 insurance policy changes.

CMS released guidance to Medicare Advantage Organizations stating that they may waive or reduce enrollee cost-sharing for COVID-19 laboratory tests, telehealth benefits, or other services to address the outbreak, as long as they do so for all enrollees on a uniform basis. Furthermore, CMS clarified that essential health benefits that are covered by nongrandfathered health plans in the individual and small group markets generally include coverage for the diagnosis and treatment of COVID-19. However, the exact coverage details and cost-sharing amounts for individual services may vary by plan.

Finally, with respect to traditional Medicare, CMS recently stated that the agency will waive Medicare beneficiaries’ cost-sharing (coinsurance and deductible) for all services that result in an order for or administration of a COVID-19 test, are related to administering such a test, or are related to the evaluation of an individual for purposes of determining the need for such a test. This includes emergency department evaluation and management (E/M) services, hospital observation services, and office and other outpatient services.

For each applicable claim, you should use the “CS modifier” and should not charge Medicare patients any coinsurance and/or deductible amounts for those services. The policy is retroactive to March 18 and lasts through the end of the COVID-19 national emergency. Thus, if you already submitted eligible claims after March 18 without the CS modifier, you can contact your local Medicare Administrative Contractor (MAC) and request to resubmit the claims with the CS modifier to get 100% payment. 

Vaccine

A COVID-19 vaccine does not currently exist. However, certain vaccines must be covered as an EHB without cost-sharing when the CDC recommends them. Under current regulations, health plans are not required to cover a new CDC-recommended vaccine until the beginning of the plan year that is 12 months after CDC issues the recommendation. However, plans may voluntarily choose to cover a vaccine for COVID-19, with or without cost-sharing, prior to that date.

The vaccine, when developed, would also be covered under Medicare.

Coding and nomenclature

For more information, see ACEP’s COVID-19 coding resources.

Regulations and Liability

State Waiver of Liability

The following 1,135 waivers have been approved by CMS as of June 3, 2020 (see also the waiver reques...

Regulations and Liability

Other Federal Updates and Guidance

For more information, see ACEP’s collated resources for other federal updates and guidance. Other F...

Personal Well-Being and Resilience

ACEP Offers, Wellness, and Counseling Services

ACEP has worked with many companies to put together COVID-19–related offers at either no cost or dis...

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