Under the recently released Interim Final Rule from the Centers for Medicare and Medicaid Services (CMS), payment rules for specimen collection are changing for the public health emergency (PHE) caused by the COVID-19 pandemic. With this change, CMS will provide payment to independent laboratories, under certain circumstances, for specimen collection from home-bound beneficiaries or inpatients not in a hospital to be tested for COVID-19. Additionally, two new Level II HCPCS codes have been released to report specimen collection for COVID-19 testing.
G2023 Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), any specimen source
G2024 Specimen collection for severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), from an individual in a SNF or by a laboratory on behalf of a HHA, any specimen source
Background on Specimen Collection
Traditionally, Medicare will pay for travel to either a nursing home or to a home-bound patient to collect blood (Social Security Act, Section 1833[h]). The fee, though nominal, is designed to cover mileage and personal expenses. However, the requirement to prorate the fees over the number of patients collected on each trip often makes this reimbursement cumbersome.
The specimen collection fee can be billed to Medicare by independent laboratories through their MAC and applies when the specimen is collected by trained laboratory personnel. It is not applicable for a specimen that could be picked up via a messenger service or for specimens patients could collect on their own.
What is Changing?
The interim final rule provided a few changes for specimen collection during the PHE for the COVID-19 pandemic:
1. The establishment of the two G-codes (listed above) to report specimen collection for COVID-19 testing with associated payment rates.
2. Defines a home-bound patient for the purposes of specimen collection during the PHE.
3. Allows for electronic mileage records for specimen collection payment during the PHE.
G-Codes and Payments
HCPCS codes G2023 and G2024 were established specifically for reporting specimen collection for COVID-19 testing. One of these codes (G2023, G2024) must be used when billing Medicare for the specimen collection fee. Code G2024 should be reported when the specimen is collected from an individual in a SNF or by a laboratory on behalf of an HHA. Code G2023 should be used for collection from home-bound patients not on behalf of an HHA. According to the COVID-19 Frequently Asked Questions document released, and often updated, by CMS:
The nominal specimen collection fee for COVID-19 testing for homebound and non-hospital inpatients generally is $23.46 and for individuals in a SNF or whose samples are collected by a laboratory on behalf of an HHA is $25.46.
When it is medically contraindicated for a patient to leave their home, they are considered “confined to their home,” or home-bound. In their FAQ document, CMS provides two scenarios where the definition of home-bound would apply during the PHE:
1. Where a physician has determined that it is medically contraindicated for a beneficiary to leave the home because he or she has a confirmed or suspected diagnosis of COVID-19; or
2. Where a physician has determined that it is medically contraindicated for a beneficiary to leave the home because the patient has a condition that may make the patient more susceptible to contracting COVID-19.
It should be noted that, in their definition for specimen collection, CMS does not consider patients who has decided to self-quarantine as homebound. In order to meet this definition for specimen collection payment to apply, the patient leaving the home must be medically contraindicated.
Electronic Mileage Records
When billing Medicare for specimen collection, the collecting laboratory is required to keep a log of the miles traveled. During the PHE, CMS is relaxing the requirement for paper documentation logs that may have been required in other circumstances. Independent laboratories billing Medicare for specimen collection for COVID-19 testing during the PHE may instead maintain electronic mileage logs. Note that these electronic logs must be able to be shared with MACs if requested.
The FAQ document provided by CMS can be found HERE. As noted, this document is updated frequently.
This situation is evolving rapidly. Guidance is current at the time of publication and may be subject to change as the situation continues to progress. It is important to continue to check sources such as the Centers for Medicare and Medicaid Services for any updates that are released.