Additional Guidance from CMS Changes Coding Methodology for COVID Patients
By Lisa Werner
In last month’s blog post, I covered coding for COVID-19. Since that time, the following additional guidance from CMS was issued that changes the methodology for coding patients with active or a history of COVID-19.
U07.1 – COVID-19: The first diagnosis code released was intended for patients diagnosed with the virus. Currently, it is used for patients with active virus. For inpatient rehabilitation providers, this code is used when a patient with active virus is in the hospital or unit. It may also be used as an etiologic diagnosis to explain why a patient was admitted. For example, a patient may present with an Impairment Group Code (IGC) of 16 and an etiologic diagnosis of U07.1.
J12.82 – Pneumonia due to COVID-19: This diagnosis was released on October 1, 2020 to capture a patient’s pneumonia secondary to COVID-19. Prior to release of this code, inpatient rehabilitation providers may have used J12.89 – other viral pneumonia to capture the presence of pneumonia following the coronavirus. J12.89 is a tier 3 condition. J12.82 is not listed as a tiering condition for inpatient rehabilitation providers. This condition should be coded as secondary to U07.1 per CMS with guidance provided to them by AHIMA.
CMS offered the following instructions: Code J12.82 cannot be reported as the primary diagnosis. If the patient still has COVID-associated pneumonia, code U07.1 should continue to be assigned, and U07.1 would be sequenced first. The “code first” note indicates that code J12.82 cannot be sequenced first. Regardless of the patient’s most recent COVID test results, code U07.1 should be assigned if the patient has a current, acute manifestation of COVID such as pneumonia.
The instructions provided by CMS are consistent with the way we treat other actively treated comorbidities on the IRF-PAI. For example, a patient may no longer have acute respiratory failure, but we would code the condition as a comorbidity when the patient continues ongoing treatment for that condition that was diagnosed in the acute phase of their hospitalization.
As noted above, in their email clarification, CMS indicated that the information provided was offered by a representative at AHIMA.