The New COVID-19 Treatments Add-On Payment (NCTAP) was finalized as part of CMS’ fourth COVID-19 Interim Final Rule with Comment Period (IFC-4).
CMS updated its coding and billing instructions for hospitals on January 27 regarding COVID-19 treatments eligible for the NCTAP. The policy was effective from November 2, 2020, through the end of the COVID-19 public health emergency.
What Is the NCTAP?
The NCTAP provided an additional payment for certain new COVID-19 treatments. The policy aimed to support hospitals that treated patients with COVID-19 using qualifying therapies.
Treatments covered under the NCTAP included:
- Remdesivir
- Convalescent plasma
- Baricitinib
Hospitals needed to report the appropriate ICD-10-PCS codes for qualifying products.
How Should Hospitals Report COVID-19 Treatments?
Hospitals should report the applicable ICD-10-PCS codes even when they obtained the treatment products at no cost.
However, hospitals should not report a charge for products acquired at no cost.
This distinction is important because coding and charging requirements can differ when hospitals receive COVID-19 treatments without payment.
How Is the NCTAP Calculated?
The NCTAP was calculated using the lesser of two amounts:
- 65% of the operating outlier threshold for the claim
- 65% of the cost of the COVID-19 stay beyond the operating Medicare payment, including the 20% add-on payment under Section 3710 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act
The calculation was designed to provide additional reimbursement for eligible COVID-19 treatments while accounting for the existing Medicare payment.
Key Takeaways for Hospitals
Hospitals billing for eligible COVID-19 treatments should pay close attention to the applicable coding and billing requirements.
Key points include:
- Report the appropriate ICD-10-PCS codes for eligible treatments.
- Report the codes even when the products were obtained at no cost.
- Do not report a charge for products received at no cost.
- Apply the NCTAP calculation based on the applicable Medicare rules.
- Review CMS updates carefully because COVID-19 payment policies changed during the public health emergency.