CMS updates regarding coronavirus lab tests

UPDATE: (March 13, 2020) Medicare Administrative Contractor (MAC) COVID-19 test pricing has been announced. Local MACs are responsible for developing the payment amount for claims they receive for the newly created HCPCs codes in their respective jurisdictions until Medicare establishes national payment rates. The payment amounts are identified in the chart below. As with other laboratory tests, there is generally no beneficiary cost sharing under original Medicare.

MAC Jurisdiction (J)	MAC States/Territories	U0001 Test Price	U0002 Test Price
J6 – National Government Services (NGS)	Illinois, Minnesota, Wisconsin	$35.91	$51.31
JK – National Government Services (NGS)	Connecticut, New York, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont	$35.91	$51.31
JH – Novitas Solutions	Arkansas, Colorado, New Mexico, Oklahoma, Texas Louisiana, Mississippi	$35.92	$51.33
JL – Novitas Solutions	Delaware, District of Columbia, Maryland, New Jersey, Pennsylvania; Part B services include Arlington and Fairfax counties in VA, and the city of Alexandria, VA	$35.92	$51.33
JN – First Coast Service Options (FCSO)	Florida, Puerto Rico, U.S. Virgin Islands	$35.92	$51.33
JJ–Palmetto Government Benefits Administrators (PGBA)	Alabama, Georgia, Tennessee	$35.91	$51.31
JM-Palmetto Government Benefits Administrators (PGBA)	North Carolina, South Carolina, Virginia, West Virginia	$35.91	$51.31
JE - Noridian Healthcare Solutions	California, Hawaii, Nevada, American Samoa, Guam, Northern Mariana Islands	$35.91	$51.31
JF - Noridian Healthcare Solutions	Alaska, Arizona, Idaho, Montana, North Dakota, Oregon, South Dakota, Utah, Washingon, Wyoming	$35.91	$51.31
J5 - Wisconsin Physician Services (WPS)	Iowa, Kansas, Missouri, Nebraska	$35.92	$51.31
J8 - Wisconsin Physician Services (WPS)	Indiana, Michigan	$35.92	$51.31
J15 - CGS	Kentucky, Ohio	$35.92	$51.31

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CMS is issuing nearly daily updates regarding its actions to support American healthcare facilities and clinical laboratories in responding to COVID-19.  

This alert provides a list of some of the more recent information provided by CMS on its current emergencies page:

Billing for COVID-19 diagnostic tests

• CMS developed a second Healthcare Common Procedure Coding System (HCPCS) code for laboratories to use to bill for certain COVID-19 diagnostic tests to help increase testing and track new cases.  
• The new HCPCS code can be used by these labs when submitting claims to Medicare or health insurers.  These codes will be accepted by the Medicare claims processing systems as of April 1, 2020, for dates of service after February 4, 2020. The various MACs are responsible for developing the payment amount for these new codes in their jurisdictions until Medicare creates the national payment rates.
• In February, CMS developed HCPCS code U0001 to bill for test and track new cases of the virus; this code is specifically for CDC testing labs;  The new HCPCS code, U0002, allows labs to bill for non-CDC lab tests for COVID-19.   

February 29, 2020, the FDA issued a new streamlined policy for certain labs to develop their own validated COVID-19 diagnostics.

On March 10, 2020, CMS sent guidance:

• To providers regarding COVID-19 in particular home health agencies and dialysis facilities.  The guidance provides information for healthcare workers regarding screening, treatment and transfer procedures to follow when working with patients.  
• To Medicare Advantage and Part D Plans to inform them about the flexibilities they have to provide healthcare coverage to Medicare beneficiaries for COVID-19 testing, treatment and prevention.  These flexibilities include waiving cost-sharing for COVID-19 tests and some treatments, removing prior authorization requirements and expanding access to certain telehealth services, among others.

To see these updates as they occur, visit the CMS website.  

Please feel free to contact the attorneys below for further information.