- CMS’s 4/30/2020 rule states that practices could bill 99211 for new or established patients during the public health emergency for COVID-19 specimen collection
- CPT had previously recommended this
- The new HCPCS codes (G2023, G2024) for COVID-19 specimen collection are for use by independent laboratories, not medical practices
The AMA developed and distributed a document that includes many scenarios for collecting COVID-19 specimens, including using 99211, a nurse visit, for collecting a specimen on a day when the patient did not have an in-person visit or telehealth visit. I disagreed with that at the time. I know that specimen collection code 99000 is not paid by most payers, and I understand that collecting this specimen costs practices significantly. But, I didn’t see that it followed coding rules. But, CMS weighed in on April 30, 2020, in their Interim Final Rule with comment (IFC).
99211 for COVID-19 specimen collection
Specifically, CMS said,
“For the duration of the COVID-19 PHE, we are therefore finalizing on an interim basis that when the services described by CPT code 99211 for a level 1 E/M visit are furnished for the purpose of a COVID-19 assessment and specimen collection, the code can be billed for both new and established patients.” CMS, in the same paragraph, notes that direct supervision for specimen collection may be met through the “virtual presence of the supervising physician or practitioner using interactive audio and video technology for the duration of the public health emergency.” 
Although CMS does not address it, I expect that if a specimen is collected on the day of an office visit, there won’t be separate payment for 99211.
Looking at the AMA scenarios (from April 3, 2020, a lifetime ago)
- Patient seen in the office, swab collected: swab collection part of E/M, can use 99000
- Patient evaluated via telemedicine or telehealth, sent to office for swab: 99211 if separate day, can use 99000
- Patient evaluated using on line digital codes 99441—99443 or virtual check in: 99211 if separate day, can use 99000
HCPCS codes G2023 and G2024 are for specimen collection by an independent lab
In the April rule, CMS notes that in the March rule they changed Medicare payment policies to allow for independent labs to be paid for specimen collection under certain circumstances. They were allowed a small payment for specimen collection during the public health emergency for collection and for associated travel. These are not for use by medical practices.
 CMS-5531-IFC, released April 30, 2020 page 188
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