99072 – new CPT® code for supplies, equipment and staff time during the public health emergency

The AMA released a new CPT^® code for use in non-facility settings for the expense related to supplies, equipment and staff time and activities for visits performed during the PHE due to respiratory-transmitted infectious disease, effective Sept 8, 2020
As of this writing, CMS has not indicated if they will assign the code an active status indicator and pay it.
For commercial payers, it isn’t known if the payer will process the claim and pay it or process it as patient-due, or process it as bundled, no payment from the company or the patient.

• 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

This code is defined as including supplies and equipment to safely treat patients during the PHE, extra sanitation activities and staff time in putting on and taking off personal protective equipment (PPE). It recognizes the additional phone and in-person time to screen patients for COVID-19 related symptoms, the additional cleaning and sanitation measures that are required, and the time it takes staff members to safely put on and take off PPE.

The code is designed to include the cost of safely caring for patients by clinical staff, during this time. The AMA developed this code in response to the significant, increased practice expenses that are a result of the PHE. Use the code in “an area where it is required to mitigate the transmission of the respiratory disease for which the PHE was declared.” The code does not require that the patient has a respiratory complaint or be diagnosed with COVID-19.

CPT^® defines it as an office or “other non-facility service.” This would include home and domiciliary care services. Use this in place of service 11, office. It may not be used for ED visits, outpatient department visits or nursing facility visits, because those are facility services. Report 99072 once/encounter, no matter how many services are performed.

CPT^® is recognizing these practice expense factors:

Additional clinical staff time to conduct pre-visit calls to screen patients, provide instructions on social distancing while at the practice, to check patients for symptoms when they arrive in the practice, put on and take off PPE, and perform additional cleaning and sanitation measures.
Three surgical masks
Cleaning supplies

The CPT Assistant goes on to say that if the activities normally performed by clinical staff are performed by the physician or non-physician practitioner, the requirement for the code will be considered to be met.

The CPT Assistant article gives one clinical scenario. It describes a patient with an acute injury or illness, or who comes to the office for treatment of chronic conditions. During the PHE, additional screening measures and equipment, as described by the code, are used. The code is billed. This tells us that the problems/diagnoses do not need to be related to the a respiratory or viral complaint.

The CPT Assistant does not suggest any specific documentation for the service.

CPT Assistant guide: Coronavirus (SARS-CoV-2); September 2020

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 3 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

But, will we be paid?

Right now, there are more questions than answers about reimbursement. Will your clearinghouse accept the code? How will the payer process it? Will using is cause the entire claim to be denied, slowing down your payments? What should you charge? Will it be patient due. While I’m glad to have a code that recognizes the significant practice expense, I wish there weren’t so many unanswered questions.

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