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As the SARS-CoV-2 virus and the incidence of COVID-19 (COVID-19) crisis increases in the U.S., guidance on how to code and report the virus has become a point of interest for those in the health information field. While many questions remain unanswered, the below timeline provides a snapshot of current published coding information.

On March 24, the American Hospital Association (AHA) published revised frequently asked questions (FAQ) for COVID-19.

On March 26, the International Classification of Diseases, Tenth Revision (ICD-10) Medicare Severity Diagnosis Related Groups (MS-DRG) Classifications and Software Version 37.1 R1 was published on the CMS website. In that update, International Classification of Diseases, Tenth Revision, Clinical Modification (ICD-10-CM) included code U07.1, COVID-19. This update is effective April 1, 2020.

To date, the interim coding guidance, which was published on February 20, 2020, hasn’t changed. To report a diagnosis of COVID-19, follow the supplemental guidance for cases discharged through March 31, 2020. For cases discharged on or after April 1, 2020, the new diagnosis code U07.1, COVID-19 should be used.

Contained within the AHA FAQ, the following question and answer have sparked many conversations in the coding community and the need for further clarification on using the new diagnosis code U07.1 for appropriate sequencing as a principal diagnosis versus a secondary diagnosis.

Question: Is the new ICD-10-CM code U07.1, COVID-19 a secondary code?

Answer: No, when COVID-19 meets the definition of principal or first-listed diagnosis, code U07.1, COVID-19, should be sequenced first, and followed by the appropriate codes for associated manifestations, except in the case of newborns and obstetrics patients.

While many questions remain, the Cooperating Parties, which include the AHA, American Health Information Management Association, CMS and National Center for Health Statistics, are working to gather information and provide clarification to the coding guidance.

This period of uncertainty is an excellent time for coders to review and refresh their understanding of the ICD-10-CM Official Guidelines for Coding and Reporting for 2020 as well as the supplemental information added for this year.

Another helpful resource to review now is the ICD-10-CM Tabular List of Diseases and Injuries April 1, 2020 Addenda. In the addenda, sequencing guidelines are addressed in the “use additional codes” instructional note.

Finally, as a reminder, when complex clinical cases appear and reviewing the coding supplements, Coding Clinics or other guidance doesn’t fully answer the questions, consider submitting a question to the AHA for clarification. Providing real-time examples of clinical situations and subsequent treatment will help the Cooperating Parties better address relevant scenarios requiring coding guidance clarification. When submitting your questions to the AHA, follow the directions to set up an account and make sure to read the Dos and Don’ts before submitting.

Due to the rapidly changing information regarding COVID-19, all guidance contained in this article is current as of the date of publication. For more information, reach out to your BKD Trusted Advisor™ or use the Contact Us form below.

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