CPT CODE 99072 ADDED FOR EXPENDITURES DUE TO PUBLIC HEALTH EMERGENCY

Editor’s note:  the ICS’ original publication of this article contained an error resulting in transposition of the CPT Code number.  The number has been corrected and the article now reflects the correct CPT Code number 99072.  We regret any confusion.

The pandemic has required healthcare offices to expend additional resources, including supplies and clinical staff time, to maximize the safety of office visits.  On September 8, 2020, the American Medical Association (AMA) published an update to the Current Procedural Terminology (CPT®) code set that includes a new code 99072 to report some of these costs.  The questions become: can we bill insurance, can we bill the patients, and is the reimbursement worth the potential challenges that may come with billing 99072?

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The “CPT® Assistant Special Edition: September Update” lists 99072 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 as defined by law, due to respiratory-transmitted infectious disease.”

The AMA reports that the addition of CPT code 99072 “…was approved in response to sweeping measures adopted by medical practices and health care organizations to stem the spread of the novel coronavirus (SARS-CoV-2), while safely providing patients with access to high-quality care during in-person interactions with health care professionals. The additional supplies and clinical staff time to perform safety protocols described by code 99072 allow for the provision of evaluation, treatment or procedural services during a public health emergency in a setting where extra precautions are taken to ensure the safety of patients as well as health care professionals.”

When and for what visits can we use this code?

First, 99072 is only to be used during a declared public health emergency due to respiratory-transmitted infectious disease. Our current pandemic does meet both requirements.

Of course, due to the nature of the costs, the code is only to be reported for in-person patient encounters and would NOT apply to telehealth visits.

What is included and what is not included?

Based on the description of included costs as “supplies, materials, and clinical staff time [emphasis added],” the ICS believes administrative staff time is not included.  For example, staff time to screen a patient is probably included because it is clinical in nature, whereas staff time spent ordering PPE is not, because it is purely administrative.

Here are examples of what would be included:

• Pre-visit phone calls – only the additional time used for this pandemic screening purposes can be used in your fee calculation. In other words, if you already call your patients in advance of their appointment, you can only use the ADDITIONAL time used for infectious disease screening in your calculation.
• In-office screening and instruction – again, only the additional time specific to the infection disease screening can be considered.
• Time to apply and remove PPE – for most chiropractic offices, this time will be very, very short and should only be considered in rare circumstances.
• Cleaning – Only the time in addition to normal cleaning practices of the examination, treatment, imaging, equipment, and supply rooms, can be considered.
• Cleaning exceptions – This code does NOT include time spent cleaning employee areas and administrative areas. Performing these tasks is not considered clinical staff time.
• Lost revenue due to cleaning time – You CANNOT include any reduction in patient volume due to cleaning time.
• PPE – Although the code includes “three surgical masks,” you cannot include these costs if you are not using the product. Only include the exact costs of the PPE you are utilizing for each patient visit (i.e. if you only use one mask per day, then the cost of one mask divided by number of visits that day).
• Cleaning supplies – This includes “additional quantities” of hand sanitizer and disinfecting wipes, sprays, and cleansers.

How much should you charge?

You should take into consideration the exact costs, and no more, associated with the above for each patient visit. You should NOT use this code as a profit center. It is an “over-and-above” cost recoupment code in pandemic situations. Those choosing to bill excessive amounts for this code could come under regulatory scrutiny from IDFPR or the state’s attorney general for over-charging or price-gouging.

Are insurers paying for this code?

Based on a recent conversation with several chiropractic leaders from around the country, we are hearing that insurers are not covering the code at this time. If you choose to bill an insurer with which you have a PPO agreement, then you are contractually obligated to only bill the patient for the patient responsibility portions. Many insurers are indicating that providers cannot balance bill patients for this code, as they consider this the current cost of doing business or incident to the other services being rendered and paid. The AMA’s addition of CPT code 99072 is an acknowledgment of required additional expenses, but it does not alter coverage of these costs under existing language of health plans and network agreements. 

When can I NOT charge for this code?

You cannot charge for this code if you are using any of your stimulus money (CARES, CARES2, or FFCRA) to cover these expenses. For example, if you choose to charge this code then you could NOT use your Provider Relief Fund monies for PPE and cleaning or any of the expenses listed above.

Should I charge this code?

In short, this becomes a business decision that you will have to personally consider. You should consider all of the factors above to help make that determination, but do not make this a profit center.

Additionally, you should consider the patient mindset now. How will your patients react? And is it worth losing a patient over what will most likely be a small charge? These are the considerations you will need to utilize when making this decision.

Doctors should take all the factors above into careful consideration when making the determination to bill for additional expenditures under CPT code 99072. At this time, the ICS is not making specific recommendations other than to follow the information above and to refrain from charging in excess of the actual additional costs.

This article is part of our covid-19 article: Coronavirus (COVID-19) In the Chiropractic Physician Office.