COVID-19 ICD-10-CM Coding Timeline for Outpatient Services

Wednesday, January 27, 2021

When COVID-19 emerged in early 2020, new ICD-10-CM codes to identify this condition were not available. Subsequent ICD-10-CM codes and guidelines for reporting COVID-19 changed many times as the pandemic evolved throughout 2020. The correct application of ICD-10-CM “Z” codes to report encounters for COVID-19 testing were particularly confusing, and coders were left to acquaint themselves—again—when new codes and guidance went into effect on January 1, 2021.

The tables below illustrate the differences in coding and reporting ICD-10-CM codes for common outpatient COVID-19 scenarios from the start of the pandemic through the release of new codes effective January 1, 2021. The tables are intended to help coding professionals ensure they are applying the applicable guidelines for coding and auditing outpatient services based on the date of service. The tables are equally useful for others who use coded data for secondary purposes. Anyone using coded claims data must take into consideration the evolving guidance in code reporting so that the data is interpreted and used correctly.

Table 1: Coding Guidelines for COVID-19 Testing
	COVID Guidelines 2/20/20¹	COVID Guidelines 4/1/20²	AHIMA FAQ 8/5/20³	New Codes Effective 1/1/21^{4, 5}
Patient has symptoms and suspected exposure to COVID-19 is ruled out	Z03.818, Encounter for observation for suspected exposure to other biological agents ruled out	No change	Z20.828, Contact with and (suspected) exposure to other viral communicable diseases	Z20.822, Contact with and (suspected) exposure to COVID-19
Patient has symptoms and confirmed (or suspected) exposure to COVID-19 w/ negative or unknown results	Z20.828, Contact with and (suspected) exposure to other viral communicable diseases	No change	No change	Z20.822, Contact with and (suspected) exposure to COVID-19
Patient has no symptoms, no confirmed (or suspected) exposure to COVID-19 w/ negative or unknown results	() Z11.59, Encounter for screening for other viral diseases; OR () Z03.818, Encounter for observation for suspected exposure to other biological agents ruled out	Z11.59, Encounter for screening for other viral diseases	Z20.828, Contact with and (suspected) exposure to other viral communicable diseases	*Z20.822, Contact with and (suspected) exposure to COVID-19
Asymptomatic individuals who test positive for COVID-19	B97.29, Other coronavirus as the cause of diseases classified elsewhere	U07.1, COVID-19	No change	No change
Patient previously had COVID-19; was seen for follow-up exam, and COVID-19 test is negative	() Z09, Encounter for follow-up exam after completed treatment for conditions other than neoplasm () Z86.19, Personal history of other infectious and parasitic diseases	No change	Z09, Encounter for follow-up exam after completed treatment for conditions other than neoplasm Z86.19, Personal history of other infectious and parasitic diseases	Z09, Encounter for follow-up exam after completed treatment for conditions other than neoplasm Z86.16, Personal history of COVID-19
Note: Asterisks () indicate that official coding guidance had not yet been published. These codes are therefore an assumption of how it was likely being reported.
Note: The new code Z11.52 (Encounter for screening for COVID-19) effective 1/1/21, is not appropriate for screening until the pandemic is declared over (per January 2021 updated guidelines I.C.1.g.1.f.).⁵ AHA will publish a notice when the COVID-19 pandemic ends.

Table 2: Application to Outpatient Testing Scenarios
Outpatient Scenario	Diagnosis Codes as of 2/20/20¹	Diagnosis Codes as of 4/1/20²	Diagnosis Codes as of 8/5/20³	Diagnosis Codes as of 1/1/21^{4, 5}
Patient presents to the ED with cough and shortness of breath. COVID-19 test is performed and result is negative. MD assessment is acute URI and patient is discharged to home.	J06.9, Acute upper respiratory infection; Z03.818, Encounter for observation for suspected exposure to other biological agents ruled out	No change	J06.9, Acute upper respiratory infection; Z20.828, Contact with and (suspected) exposure to other viral communicable diseases	J06.9, Acute upper respiratory infection; Z20.822, Contact with and (suspected) exposure to COVID-19
Patient presents to the ED with fever and cough after spending the weekend caring for an elderly aunt with COVID. COVID-19 test is performed and result it negative. MD assessment is acute URI and patient is discharged to home	J06.9, Acute upper respiratory infection; Z20.828, Contact with and (suspected) exposure to other viral communicable diseases	No change	No change	J06.9, Acute upper respiratory infection; Z20.822, Contact with and (suspected) exposure to COVID-19
A patient presents to the physician clinic requesting COVID-19 test due to being exposed to COVID-19 by a family member. The patient has no symptoms and the test is negative.	Z11.59, Encounter for screening for other viral diseases; OR Z03.818, Encounter for observation for suspected exposure to other biological agents ruled out	Z11.59, Encounter for screening for other viral diseases	Z20.828, Contact with and (suspected) exposure to other viral communicable diseases	Z20.822, Contact with and (suspected) exposure to COVID-19
A patient presents to the physician clinic requesting COVID-19 test. The patient has no symptoms and no known or suspected exposure. The test is negative.	Z11.59, Encounter for screening for other viral diseases	Z11.59, Encounter for screening for other viral diseases	Z20.828, Contact with and (suspected) exposure to other viral communicable diseases	Z20.822, Contact with and (suspected) exposure to COVID-19
Patient comes in for outpatient removal of squamous cell carcinoma of the skin of the nose. The patient has no COVID-19 symptoms, but routine testing is done and the test is negative.	C44.301, Unspecified malignant neoplasm of skin of nose; Z11.59, Encounter for screening for other viral diseases	No change	C44.301, Unspecified malignant neoplasm of skin of nose; Z20.828, Contact with and (suspected) exposure to other viral communicable diseases	C44.301, Unspecified malignant neoplasm of skin of nose; Z20.822, Contact with and (suspected) exposure to COVID-19

Notes

Centers for Disease Control and Prevention. “Coding encounters related to COVID-19 Coronavirus Outbreak.” ICD-10-CM Official Coding Guidelines – Supplement. February 20, 2020. https://www.cdc.gov/nchs/data/icd/ICD-10-CM-Official-Coding-Gudance-Interim-Advice-coronavirus-feb-20-2020.pdf.
Centers for Disease Control and Prevention. “ICD-10-CM Tabular List of Diseases and Injuries.” April 1, 2020 Addenda. https://www.cdc.gov/nchs/data/icd/10cmguidelines-FY2020_final.pdf
American Health Information Management Association. “AHIMA and AHA FAQ: ICD-10-CM/PCS Coding for COVID-19.” March 20, 2020. Updated December 14, 2020. https://journal.ahima.org/ahima-and-aha-faq-on-icd-10-cm-coding-for-covid-19.
Centers for Disease Control and Prevention. “International Classification of Disease, Tenth Revision, Clinical Modification (ICD-10-CM).” Web page. Accessed on 12/18/20. https://www.cdc.gov/nchs/icd/icd10cm.htm.
Centers for Disease Control and Prevention. “ICD-10-CM Official Guidelines for Coding and Reporting FY 2021 – UPDATED January 1, 2021.” October 1, 2020 – September 30, 2021. https://www.cdc.gov/nchs/data/icd/ICD-10cmguidelines-FY2021-COVID-update-January-2021-508.pdf.

Additional References

Centers for Medicare and Medicaid Services and the National Center for Health Statistics. ICD-10-CM Official Guidelines for Coding and Reporting FY 2021. https://www.cdc.gov/nchs/data/icd/10cmguidelines-FY2021.pdf

American Hospital Association Coding Clinic 2020 2Q, 3Q, 4Q.

Mary H. Stanfill (mstanfill@uasisolutions.com) is vice president of consulting services at United Audit Systems, Inc.

Patricia Maccariella-Hafey (patmacc@hiacode.com) is executive director of education for Health Information Associates, a national healthcare consulting firm specializing in coding compliance review, education and contract coding services.

Christi LeBlanc (christina.leblanc@hcahealthcare.com) is a Senior Coding Compliance Consultant at HCA Healthcare.

Janice Noller (jrnoller@outlook.com), recently retired, was most recently the inpatient coding educator at University of Utah Hospital.

Tags: coding and reimbursement , coronavirus , COVID-19 , ICD-10-CM , coding guidelines