AHCA Update: CMS Issues Claims Processing Guidance Related to New COVID-19 ICD-10 Code

AHCA reported to CMS an apparent glitch with implementing the U07.1 - 2019-nCoV acute respiratory disease ICD-10 CM code when the five-day assessment window overlaps March into April dates of service. For example, when the MDS assessment reference date (ARD) is in April [4/1/20], but the date of service (DOS) is in March [3/25-3/31]. This is creating a problem given the U07.1 code is valid as primary in the MDS grouper April 1 but not on the UB-04 for DOS prior to April 1. Specifically, this is creating a primary diagnosis conflict whereby providers cannot match the primary diagnosis on the UB-04 in form locator 67 with the primary reason for skilled care in item I0020B of the MDS. CMS has provided the following standardized guidance to the MACs:

“Based on the following guidance from the CMS PDPM FAQs question 1.8 is to tell providers with a 5-Day PPS MDS with an April 2020 ARD, but a lookback period that extends into March 2020 that, when applicable, they can use the COVID 19 ICD-10 code U07.1 in MDS item I0020B to obtain the appropriate PDPM case-mix classification, but that the claim associated with March DOS must contain a different ICD-10 code that applies to the beneficiary and that was valid in March.
“We understand that this is a one-time event that only impacts a relatively small number of admissions related to COVID-19 that spanned the March-April implementation of the new U07.1 diagnosis code. The claim will need to contain a different diagnosis other than U07.1 but the assessment may contain U07.1 code in these instances.”

AHCA recommends providers to share the above with billing staff.