Everything You Need to Know About the 99072 CPT Code

During the COVID-19 pandemic, the US government (and CMS) created a slew of new legislation to help medical professionals weather the storm during the public health emergency (PHE). In September 2020, the American Medical Association (AMA) created 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! 

But in case you missed it, the PHE ended on May 11, 2023. That does not mean the CPT code 9072 disappeared—but it does mean the criteria to be reimbursed for the code no longer applies.  But since it is still in the lexicon of usable CPT codes for PTs, OTs, and SLPs—and CPT coding is no stranger to confusion—we have this quick post on everything you need to know about CPT code 99072. 

What is CPT code 99072?

CPT code 99072 was created to allow for reimbursement of personal protective equipment (PPE) and other infection control costs during the PHE. 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 has ended, the code lives on in case of future health emergencies. 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

When a PHE is declared, 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 contact payers individually to get a pulse on their documentation requirements. 

Which insurance carriers pay for 99072?

As we mentioned at the beginning of this post, the PHE is no longer active, so the criteria to seek reimbursement from any payer is technically no longer valid. That said, many practices and healthcare institutions are still using PPE during flu season and ongoing care related to COVID-19. As such, they may be using the code for reporting and tracking purposes, and depending on your practice type and state, this may have some utility for your practice.

To determine if your state and local commercial carriers are paying for 99072, you’ll 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 for many years to come.