Everything PTs Need to Know About 99072

The COVID-19 pandemic has put an undue amount of strain on medical professionals across the country—emotionally, physically, and (for those who run clinics) financially. In response, the US government (and CMS) created a slew of new legislation to help medical professionals weather the storm. In September, the American Medical Association (AMA) joined the cause by creating a new CPT code (99072) to help clinicians seek compensation for the cost of providing medical care during the COVID-19 public health emergency. Those disposable masks and bottles of hand sanitizer don’t come cheap, you know! 

Since then, PTs, OTs, and SLPs have been clamoring for more information about this new CPT code: how it works, how to bill it, and who pays for it. Well, if you’re one of those aforementioned rehab therapists, your clamor (and search) has come to an end. Here’s everything you need to know about CPT code 99072. 

What is CPT code 99072?

Medical providers can bill 99072 to seek reimbursement for personal protective equipment (PPE) and other infection control costs. According to CMS, the official description for 99072 is as follows: “Additional supplies, materials, and clinical staff time over and above those usually included in an office visit or other non-facility service(s), when performed during a Public Health Emergency as defined by law, due to respiratory-transmitted infectious disease.”

But what items and actions does that cover, exactly? Well, compliance consultant Rick Gawenda says that in addition to covering expenses associated with PPE and cleaning and disinfecting supplies, this code accounts for the time it takes to:

• screen patients, 
• don and doff PPE, and
• clean and sanitize treatment areas and equipment. 

When and how do I bill CPT code 99072? 

When to Bill 99072

Per the AMA, providers can bill 99072 “with an in-person patient encounter for an office visit or other non-facility service, in which the implemented guidelines related to mitigating the transmission of the respiratory disease for which the PHE was declared are required.”

Put simply, that means providers can bill this code: 

• during an official public health emergency (PHE), 
• when they see a patient in-person, and
• in outpatient settings only.

While the current public health emergency will eventually end, this code could live on. The AMA specifies that providers may use code 99072 during future PHEs if “health and safety conditions applicable to a PHE require the type of supplies and additional clinical staff time explained in the code descriptor.” 

How to Bill 99072

Billing this code is relatively straightforward. To our knowledge, it doesn’t require any modifiers, and it can be billed with any diagnosis code. 99072 is an untimed unit, and outpatient providers can bill it “once per in-person encounter.” In other words, providers will only ever bill one unit of 99072 at a time. 

As with any other CPT code, 99072 does have documentation requirements. When it comes to documenting the cost of the PPE you use, Gawenda recommends accounting for and noting these expenses wherever the clinic tracks its finances (e.g., Quickbooks). In terms of tracking clinic time that’s dedicated to infection control, Gawenda recommends documenting all infection control protocols, from administering patient questionnaires and cleaning shared areas to donning and doffing PPE.

That said, the American Academy of Orthopaedic Surgeons warns: “Documentation requirements and coverage may vary among payers.” So, rehab therapists should reach out to payers individually to get a pulse on their documentation requirements. 

Which insurance carriers pay for 99072?

Remember the beginning of the pandemic—when we answered every question about telehealth coverage with “it depends”? Well, unfortunately, that’s where we are again.

During its quarterly update to the Medicare Physician Fee Schedule, CMS announced that it does not currently plan to pay for 99072. So, at the very least, CMS won’t pay for this code through the end of 2020. The agency has also clarified that there are no RVUs associated with 99072, which means there’s no national payment standard for commercial or state payers to follow if they do choose to cover this code. Because of all this ambiguity, commercial payers and state Medicaid programs have not come to a consensus about covering CPT code 99072. Some payers have chosen to follow CMS’s lead and deny reimbursement, while others have reportedly chosen to pay for this code.  

To find out if your state and local commercial carriers are paying for 99072, you’ll ultimately have to contact them individually. 

Limitations

If your commercial payers decline to pay for 99072, be wary of charging patients cash for this code. According to the APTA, some state laws “restrict the application of surcharges for additional supply expenses associated with the public health emergency.” (In other words, you can’t charge patients for PPE.)

Do I have to bill and document for 99072 even if my payers aren’t reimbursing this code?

To our knowledge, no. This code was created as a tool to help providers recoup costs—not to enact another burdensome billing requirement. You do not have to bill this code if you don’t want to—and you should seriously consider the pros and cons of billing it to payers that won’t cover it. In this Q&A, Gawenda encourages providers to think before they bill, saying “is it even worth billing the CPT code and maintaining the required documentation to bill this CPT code. This is a decision for the practice owner to make.”

That said, it’s not a bad idea for clinics to continue tracking how much money they’re spending on PPE, as it will continue to be a mainstay in healthcare settings for several months—and possibly even years.

So, what do you think? Do you feel confident about billing CPT code 99072? Have more questions you’d like to ask? If you’re itching for more info, feel free to drop a comment below.