​ Thank you for your questions about administration of the COVID-19 vaccine during an office visit billed using CPT codes 99202, 99203, and 99204.   These CPT codes are included in encounter value sets used by many eCQMs to identify qualifying encounters for the initial population and denominator population. As indicated in the description for each code, they are intended for use with office or other outpatient visits for the evaluation and management of new patients, and require three key components: a patient history; an examination; and medical decision making. As such, if one of these codes is used for a visit, the expectation is that these three key components would be completed.   While a visit only for administration of a COVID-19 vaccine may not require these three key components be completed, if the encounter code used for the visit is CPT code 99202, 99203, or 99204, the patient may qualify for an eCQM that uses these codes to identify the denominator population. If the patient meets requirements for an eCQM they can only be excluded from the measure based upon the denominator exclusions and exceptions for the specific measure. You should not exclude a patient case from any eCQMs for reasons other than those defined in the respective measure. If the patient does not meet denominator exclusion or exception criteria then they must meet the numerator requirements to pass the respective measure.   For the Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention eCQM, CMS138, if the patient is 18 years and older and seen for at least two visits or at least one preventive visit during the measurement period, they qualify for the measure. The 99202, 99203, and 99204 CPT codes are in the Office Visit value set (2.16.840.1.113883.3.464.1003.101.12.1001) and there would need to be at least two visits during the measurement period using these codes for the patient to qualify for the measure. CMS138 does not have any denominator exclusions. CMS138 denominator exceptions are documentation of medical reason(s) for not screening for tobacco use OR for not providing tobacco cessation intervention for patients identified as tobacco users, and can apply if the patient is not screened for tobacco use or if they are screened as a tobacco user and are not provided a tobacco cessation intervention. A denominator exception will remove the patient case from the measure. If the screening or intervention are not performed, and there is no documentation of a medical reason for not screening or providing an intervention, the patient case will not meet the measure requirements.   For information related to codes for use with COVID-19 vaccinations we refer you to the CMS Coding for COVID-19 Vaccine Shots at https://www.cms.gov/medicare/covid-19/coding-covid-19-vaccine-shots . This site includes the CPT codes for the vaccines and their administration. From this site you can also review a toolkit that includes details on COVID-19 vaccine Medicare coding structure, and Medicare payment rates for administering COVID-19 vaccines.

With the Covid-19 Vaccine rapidly being administered, we are receiving some questions on whether to exclude these patients from certain measures because of the Office Visit value set charges for the vaccine administration. For example, CMS-138 has an Office Visit with CPT Codes 99202, 99203, and 99204 which may be associated with a patient simply coming in for their Covid-19 vaccine. Are we expecting physicians to complete these assessments (such as Smoking assessment) during the covid vaccine administration visit to meet the measures with an Office Visit value set associated? The issue that can occur for this scenario is that the visit may just be for the Covid-19 administration and these patients would still qualify for the denominator of CMS 138 but not the numerator (because no smoking assessment screening is done) and could therefore negatively impact reporting information due to billing the office visit with a CPT code referenced by another CMS eCQM measure. Do you have any guidance on whether office visits scheduled to administer the covid vaccine should be excluded from qualifying for certain measures? Or should the quality measure actions (like smoking assessment for this example) be taken during these Covid-19 vaccine administration office visits? Or will there be new CPT codes offered specifically for Covid-19 vaccine administration visits? Any guidance on the covid vaccine administration visit code would be appreciated.