Q&A: Following HRSA billing guidance for treating uninsured COVID-19 patients

Q: I listened to a recent webinar from the Health Resources and Services Administration (HRSA) regarding its program for reimbursing hospitals treating uninsured COVID-19 patients. However, our revenue cycle department is still confused after reading a follow-up Q&A. HRSA says that COVID-19 diagnoses must be in the primary/principal diagnosis field for hospitals to be reimbursed for treatment of uninsured patients, but this violates the coding guidance we’ve received from CMS and Coding Clinic. How should we handle such claims?

A: Hospital coders must always follow coding guidelines, but as revenue cycle and reimbursement professionals know, payers may have additional claim and reimbursement rules that must be followed for claims to be appropriately paid. 

In these Q&As, HRSA implies that if the patient is uninsured and had COVID-19, it will reimburse claims when the COVID-19 diagnosis is in the primary position on the claim. This appears to be a claim processing rule that they are asking hospitals to follow when appropriate.

HRSA is not a HIPAA-covered entity, so the hospital would not be violating coding rules by resequencing the codes when they submit to HRSA. If the case meets the definition of a COVID-19 diagnosis, put one of the COVID-19 diagnosis codes in form locator 67.

It’s also a good reminder to CDI professionals that records of all patients, especially the uninsured, should be reviewed to ensure documentation supports accurate capture of the appropriate codes related to:

• Z03.818, encounter for observation for suspected exposure to other biological agents ruled out (possible exposure to COVID-19)
• Z11.59, encounter for screening for other viral diseases (asymptomatic)
• Z20.828, contact with and (suspected) exposure to other viral communicable (confirmed exposure to COVID-19) 

Often, self-pay records are not reviewed or prioritized by CDI professionals. This program stresses this practice should be changed.

Editor’s note: This question was answered by Valerie Rinkle, MPA, CHRI, regulatory specialist for HCPro in Middleton, Massachusetts, Laurie L. Prescott, RN, MSN, CCDS, CDIP, CRC, CCDS-O, CDI education director at HCPro, and Shannon McCall, RHIA, CCS, CCS-P, CPC, CEMC, CRC, CCDS, HCS-D, director of HIM and coding for HCPro.

This answer was provided based on limited information. Be sure to review all documentation specific to your own individual scenario before determining appropriate code assignment.