CPT Code 99072, Introduced for COVID-19, Finalized as Bundled Service by CMS

In a time when a trip to the nail salon requires a temperature check before entry, it comes as no surprise that medical providers across the globe have implemented extra protocols to keep physicians and their patients safe.  Since the start of the COVID-19 pandemic, medical providers have been forced to incur additional (and sometimes, substantial) costs associated with increased sanitization measures and personal protective equipment (PPE).

In an effort to alleviate COVID-19-related costs, the American Medical Association (AMA) created an additional supply code under CPT Code 99072, defined as: “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 (PHE) as defined by law, due to respiratory-transmitted infectious disease.”[1] According to the Centers for Medicare & Medicaid Services (CMS),  the COVID-19 PHE was determined to exist nationwide as of January 27, 2020.[2]

Code 99072 became effective on September 8, 2020.  It is intended to be reported only once – per – encounter by a physician or other non-facility, only during a PHE, and only for “additional items required to support a safe in-person provision of evaluation, treatment, or procedural service(s),” which could include “the additional time required by clinical staff to provide the service safely.” [3]

Insurers and third-party payers can expect to receive reimbursement requests for 99072.  The AMA provided one clinical example of appropriate billing for 99072, as follows: “A 65-year-old female presents to the physician’s office, requiring care for an illness, acute injury, or ongoing care for a chronic condition. The encounter occurs during a Public Health Emergency (PHE), as defined by law, due to respiratory-transmitted infectious disease.”[4] The AMA CPT Assistant does not specify what documentation would be sufficient to substantiate reimbursement of 99072, but notes that the required documentation for reimbursement of 99072 will likely vary between third-party payers and individual insurers.

[1]           See American Medical Association (AMA) CPT Assistant, Special Edition September Update, (Vol. 30, Sept. 2020) https://www.ama-assn.org/system/files/2020-09/cpt-assistant-guide-coronavirus-september-2020.pdf.

[2]           See Centers for Medicare & Medicaid Services (CMS), Health and Human Services (HHS), 2021 Medicare Payment Fee Schedule (MPFS) Final Rule, 85 FR 84472, 84692 (Dec. 28, 2020) https://www.federalregister.gov/documents/2020/12/28/2020-26815/medicare-program-cy-2021-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part

[3]           See American Medical Association (AMA) CPT Assistant, Special Edition September Update, (Vol. 30, Sept. 2020) https://www.ama-assn.org/system/files/2020-09/cpt-assistant-guide-coronavirus-september-2020.pdf.

[4]           Id.