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Medicare enables COVID-19 ICD-10 code for Section 111 reporting

As the COVID-19 pandemic continues, questions are surfacing regarding associated coding for the illness for Section 111 reporting activities.

On this point, the Centers for Disease Control and Prevention (CDC) issued a bulletin advising it is implementing the new ICD-10 U07.1 for “COVID-19, virus identified” in an off-cycle update effective April 1, 2020, to code the COVID-19 diagnosis. This coding update was originally scheduled to become effective on October 1, 2020, but, as noted, has now been accelerated for usage effective April 1, 2020.

In terms of Section 111 reporting, since U07.1 was newly adopted by the CDC, it wasn’t initially included in the list of accepted Section 111 codes and was not immediately available for use. Medicare needed to first add the code into its system before it could be accepted. While CMS has not issued a formal updated Section 111 Alert, we have learned that the Benefits Coordination and Recovery Center (BCRC) has recently added U07.1 to the list of accepted codes for all insurance types under Section 111 reporting and that Responsible Reporting Entities (RREs) can now use it for Section 111 reporting requirements. Of note, only U07.1 is currently accepted for reporting, and the U07.2 code “COVID-19, virus not identified” has not been added to the Section 111 list of accepted codes.

We will continue to provide subsequent updates as warranted. In the interim, please do not hesitate to contact me if you have any questions.


Sid Wong, J.D.

Sid Wong is the Vice President of Policy at Verisk Casualty. In this capacity Sid monitors and evaluates the changing state of Medicare Secondary Payer compliance to develop impactful solutions to emerging MSP issues and works to ensure that Verisk’s Casualty’s policies, products, and services continue to align with the MSP landscape. He also oversees Verisk Casualty’s policy team, which provides policy and compliance support for all of Verisk Casualty’s clients. During his tenure he has served as Legal Director, Assistant Director of Services, Client Solutions Manager, and MSP Compliance Manager. Sid is a subject matter expert on MSAs, Conditional Payment Recovery, and Section 111 reporting. He collaborates with clients to develop best practices and respond to any compliance or policy questions, whether it’s a case level issue or evaluating a process impacting the larger organization. He regularly presents at industry conferences and provides training for clients.

Prior to joining Verisk, Sid worked for a small general practice firm in New Hampshire where he received his JD from University of New Hampshire Franklin Pierce School of Law. Sid is a member of the MA, NH, and NY bar, the IAIABC, NAMSAP, MARC, and is MSCC certified.


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