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News Alert: COVID-19 Prompts NUBC to Add New Code

NUBC guidance has been updated with the missing ICD-10-AHA code for screening: Z11.59.

EDITOR’S NOTE: During recent weeks, the Centers for Medicare & Medicaid Services (CMS) has been announcing revisions to its regulatory requirements on a near-daily basis, in an attempt to ease administrative and logistical burdens on providers amid the ongoing COVID-19 pandemic. As such, articles published on one day may later be found to contain outdated information just several days later. and are committed to providing comprehensive coverage of these changes as they continue to be made, so please stay tuned as new developments unfold. 

There had been four codes that fulfilled the requirements to attach the “DR” condition code earmarking COVID-19 for the government:

  • B97.29, Other coronavirus as the cause of diseases classified elsewhere (for services provided prior to April 1)
  • U07.1, COVID-19 (for services provided from April 1 on)
  • Z03.818, Encounter for observation for suspected exposure to other biological agents ruled out
  • Z20.828, Contact with and (suspected) exposure to other viral communicable

Z03.818 is problematic, and it elicited my contact with the Centers for Medicare & Medicaid Services (CMS). One of our Talk Ten Tuesdays listeners, Sheri Simoni, pointed out this nuance to me in a question following my COVID-19 TalkBack segment.

Per the ICD-10-CM Official Guidelines for Coding and Reporting, it seems that the Z03 observation codes are only supposed to be used as a principal or first-listed diagnosis. In addition, if there are signs or symptoms related to the suspected condition or problem that is ruled out, the signs or symptoms are supposed to be the diagnosis. Therefore, in order to use Z03.818, in the case of COVID-19, the patient must be asymptomatic and exposure needs to be ruled out.

Amid the pandemic, it is difficult to unequivocally rule out exposure, so I had trouble thinking of situations in which Z03.818 might apply. The situations posed to me as potential candidates were the following:

  1. A patient comes to the hospital for something unrelated (like an appendectomy or heart attack), but the hospital needs to check if they have COVID-19 to determine where they should be admitted – and whether they are a potential source of exposure for staff.
  2. A family member of a patient at a facility informs the facility that they have COVID-19 (when there is no lockdown on the facility, of course). The entire facility gets tested. This is not a routine screening; it is a targeted investigation with potential or ruled-out exposure.

The first scenario doesn’t satisfy the guidelines, because the PDx would be the alternate reason for admission (e.g., MI, appendicitis), and Z03.818 can’t be secondary.

For the second scenario, there is another code, Z11.59, Encounter for screening for other viral diseases, which I considered, but discounted. Screenings are for asymptomatic patients who are being routinely checked to discover early disease; think routine mammograms or biannual TB tests. If a patient has symptoms, it is no longer a screening test, but a diagnostic one.

Another situation that could pose a problem would be the patient with symptoms who could represent COVID-19 as well as other respiratory conditions, but the provider determines after study that there is no chance the patient was exposed. This is unlikely right now, in the midst of the pandemic, but in the future, it could be a more common occurrence.

I have petitioned CMS to have Z03.818 have the same dispensation as Z03.7-. The code needs to be used as a secondary diagnosis. It should be acceptable to have it as an additional code to signs and symptoms.

The other issue is what to do in the case of true screening. If we had enough COVID-19 tests, we would be screening huge swaths of the population to determine the true prevalence and to identify affected patients to quarantine them. In the future, nursing homes may do a routine screen of every patient being admitted, even when there is no longer a pandemic and a high risk of infection. Prior to the update, Z11.59 was not eligible for the DR condition code to receive reimbursement for COVID-19-related services.

I received word recently that Z11.59 was added to the NUBC list!

There are other codes we need to add to ICD-10-CM to be able to code and monitor COVID-19. I’d love to see the following:

  • U07.2, COVID-19, virus not identified – the World Health Organization (WHO) has this one in ICD-10. It is for non-laboratory-confirmed COVID-19 (i.e., pending) and clinically and epidemiologically suspected COVID-19. U07.1, COVID-19, virus identified, plus U07.2 constitute the cohort of patients who are considered to have COVID-19.
  • COVID-19 as its own screening code: Z11.52, Encounter for screening for COVID-19
  • Z86.16, Personal history of COVID-19
  • R76.8_ A child code of “Other specified abnormal immunological findings in serum” that represents immunity to COVID-19

The bottom two bullets are needed once we transition to widespread antibody testing so we can surveil COVID-19. We don’t know the extent or duration of immunity.

CMS has been doing a good job of riding this crazy tidal wave of change. I hope we can keep the momentum up. Feel free to let the agency know your thoughts on this matter via email at:

Programming note: Listen to Dr. Erica Remer every Tuesday on Talk Ten Tuesdays, 10-10:30 a.m. EST.

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Erica E. Remer, MD, CCDS

Erica Remer, MD, FACEP, CCDS, has a unique perspective as a practicing emergency physician for 25 years, with extensive coding, CDI, and ICD-10 expertise. As physician advisor for University Hospitals Health System in Cleveland, Ohio for four years, she trained 2,700 providers in ICD-10, closed hundreds of queries, fought numerous DRG clinical determination and medical necessity denials, and educated CDI specialists and healthcare providers with engaging, case-based presentations. She transitioned to independent consulting in July 2016. Dr. Remer is a member of the ICD10monitor editorial board and is the co-host on the popular Talk Ten Tuesdays weekly, live Internet radio broadcasts.

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