The next COVID-19 coding update: More like a planned emergency?

Oct. 2, 2020 / By Rhonda Butler

Hopefully October 1 came and went for you as normally as could be expected—considering we are beginning fiscal year 2021 during the biggest health care emergency of our lifetimes. Typically, the annual update of health care policies and codes on October 1 is the most important day of the year in terms of changes going into effect. At least we can count on the new fiscal year happening when it says it will—hurray for October 1!  Not so with emergency updates—they happen when they happen. The next round of emergency COVID-19 codes is already on the docket, but this time the industry is being given a longer lead time as well as time to comment on the proposed codes. Sort of a planned emergency update.

Several new ICD-10-CM codes for conditions and services associated with COVID-19, including a new code specifically for pneumonia due to COVID-19, were proposed at the September ICD-10 Coordination & Maintenance Committee meeting, held via Zoom on September 8 and 9. Instead of an April 1 implementation date (October 1 and April 1 are the only non-emergency dates allowed), the proposed implementation date for these codes is January 1. Verbal public support during the meeting was strong for the proposed codes, so it is likely that we will have another update of ICD-10-CM codes, coding guidelines, DRGs and all the rest on January 1.

The recorded meeting where the codes are proposed and discussed is available on the CDC website. However, since the meeting recording is a rather painful seven hours, it puts you at risk of acute-onset Zoom fatigue if you are not already a chronic sufferer (The passcode to access the recording is 2C$4Y8^O. Copying and pasting the passcode is taken by me as informed consent). You could download the PDF of the topic packet to see the full written proposals, but be warned that the topic packet is 118 pages long, contains 30 other topics unrelated to COVID-19, and is in alphabetical order, not chronological order, so it doesn’t track with the Zoom recording.

Below is a summary version for people short on time and who are only interested in the proposed COVID-19 codes. I also include the Zoom timestamp and PDF page number in case you want to look at a specific proposal in more detail.

Multisystem Inflammatory Syndrome (MIS)


Named in April of 2020, MIS identifies a severe inflammatory syndrome first recognized in the UK as manifesting in children and associated with current or recent SARS-CoV-2 infection. According to the current CDC case definition, the syndrome includes fever, lab evidence of inflammation and clinical evidence of severe illness that requires hospitalization with at least two organ systems involved. It is also defined by lab evidence of SARS-CoV-2 or a history of known exposure to a suspected or confirmed COVID-19 case within 4 weeks prior to symptom onset. There are also reports of the syndrome occurring in adults—patients with a recent history of COVID-19 with features of inflammation and organ dysfunction in the context of recent COVID-19 infection.

Code proposal

The proposed new code is M35.81 Multisystem inflammatory syndrome, with alternate terms in the tabular for MIS-C (Multisystem inflammatory syndrome in children) and PIMS (Pediatric inflammatory multisystem syndrome).

For more info

The Zoom recording starts at around 6 minutes (timestamp 00:06:00) and goes till about 50 minutes (timestamp 00:50:00). The presentation is by Angela Campbell, MD, MPH, of the National Center for Immunization and Respiratory Diseases at the CDC. The full written proposal is in the topic packet beginning p. 67.

COVID-19 Z codes


In response to requests from the industry, NCHS/CDC proposes to create specific codes for reporting COVID-19 screening, exposure, and personal history respectively. The proposed codes are:

  • Z11.52 Encounter for screening for COVID-19
  • Z20.822 Contact with and (suspected) exposure to COVID-19
  • Z86.16 Personal history of COVID-19

For more info

The Zoom recording starts immediately after the MIS topic at around 50 minutes (timestamp 00:50:00) and goes on for…a while. There is no formal slide presentation, only a verbal review of the proposal by David Berglund, MD of the NCHS/CDC. The written proposal is in the topic packet on p. 26, but it does not yet contain any content besides the codes (e.g., exclusions, “code also” notes). Presumably NCHS is waiting for public input.

Pneumonia due to COVID-19


Interim guidelines instruct coders to report two diagnosis codes for pneumonia due to SARS-CoV-2—U07.1 COVID-19 for the infection and a second code for the pneumonia, J12.89 Other viral pneumonia. According to analysis cited in this proposal using CMS data and CDC mortality data, less than 50 percent of the CMS records and fewer than half of the deaths recorded in the CDC’s mortality data listed the pneumonia code on the record. Since COVID-19 is primarily a respiratory disease, this suggests the coded records may be substantially underreporting pneumonia-related COVID-19. Therefore, the FDA is requesting a pneumonia code specific to COVID-19 to enable more accurate surveillance of COVID-19 related pneumonia.

Code proposal

The proposed new code is J12.82 Pneumonia due to coronavirus disease 2019 with “includes notes” for alternate terms “Pneumonia due to COVID-19” and “Pneumonia due to 2019 novel coronavirus (SARS-CoV-2).”

For more info

The Zoom recording for this topic was the last one of the day—and jinxed by technical difficulties. After many attempts to quell the echo-y feedback from the presenter’s phone, there is a very brief presentation at around 11 minutes from the end of the recording (timestamp 06:49:00). The entire topic—slide presentation, review of proposed change, comments/questions from the audience—lasts about ten minutes (timestamp 06:59:00). The presentation is by Mikhail Menis, PharmD, MS, from the Office of Biostatistics and Epidemiology at the FDA. The full written proposal is in the topic packet beginning p. 76.

If you have already sent your comments to CDC, bravo you. If others are interested in commenting on these proposed changes, you have until October 9 to submit written comments. Send them to and give yourself a generous pat on the back for exercising your right to participate in the work of government.

Rhonda Butler is a clinical research manager with 3M Health Information Systems.

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