Coding for COVID-19: Updated advice not included in the official coding guidelines

June 1st, 2020 / By Audrey Howard

With the beginning of a new month, I can’t help but reflect on some of the remarkable events that have occurred in the last several weeks related to ICD-10-CM. Coding advice on COVID-19 has been updated and revised frequently, which has raised questions and some confusion among coders. Because of these unprecedented times, we have received a few reader comments with concerns about which coding advice to follow and if the published FAQs in the American Hospital Association (AHA) Coding Clinic Advisor and American Health Information Management Association (AHIMA) websites conflict with the official coding guidelines.

A reader of one of my previous blogs asked about adding code Z20.828, Contact with and (suspected) exposure to other viral communicable diseases, as a secondary diagnosis on patients who have symptoms with a negative COVID-19 test. The reader noted that the official coding guidelines on COVID-19 do not include the directive to add this code when the known exposure is not documented. The FAQ on the AHA/AHIMA websites states that because we are in a pandemic, it is appropriate to use this code. The reader disagreed with the FAQ advice since it was not addressed in the guidelines that were established after the pandemic was announced. 

I can understand these concerns. It can be challenging to keep up with the changing advice, even for the official mechanisms responsible for the publication of the guidelines. Typically, the official coding guidelines are updated once a year, effective October 1, and Coding Clinic is published four times a year.  Even though official coding guidelines were published for COVID-19 (for both interim coding and post implementation of code U07.1), it has been difficult to anticipate all the real-life scenarios that need to be addressed.  As a result, both AHA and AHIMA are jointly publishing the FAQs to keep up with requests for additional support.  Please note that AHA and AHIMA are two of the four cooperating parties that approve the official coding guidelines and advice published in Coding Clinic. The National Center for Health Statistics (NCHS) and the Centers for Medicare and Medicaid Services (CMS) are the other two organizations involved. The cooperating parties work closely together to ensure that clear and consistent advice is given. Therefore, even though the advice published in the FAQs is not a part of the official coding guidelines, I believe it is appropriate to follow. The AHA Coding Clinic Advisor website, an extension to AHA Coding Clinic for ICD-10-CM/PCS, states, “The only publication endorsed by HCFA [now called CMS] is the Coding Clinic for ICD-9-CM [which is now ICD-10-CM/PCS] published by AHA.” (AHA Coding Clinic for ICD-9-CM, 1989 4Q, p. 3.)

In addition, the AHA/AHIMA FAQ advice to use code Z20.828 as a secondary diagnosis when there is no known exposure or not documented is somewhat supported in the “regular” official coding guidelines, which states a code from category Z20 can be used “where a disease is epidemic.” 

The use of code Z20.828 in these situations allows coders to track when COVID-19 testing is negative regardless of signs and symptoms and exposure to the disease.

If you are still concerned about which coding advice to follow, I suggest submitting a question directly to AHA Coding Clinic to get an individual response.

In the end, the final decision regarding the codes submitted on the claim is yours. The views included in this blog are not a substitute for informed judgment by your facility.

Audrey Howard, RHIA, is a senior outsource services consultant with 3M Health Information Systems.

Click here to visit the 3M HIS COVID-19 resource page.


During a pandemic, healthcare information is gathered, studied, and published rapidly by scientists, epidemiologists and public health experts without the usual processes of review. Our understanding is rapidly evolving and what we understand today will change over time. Definitive studies will be published long after the fact. 3M Inside Angle bloggers share thoughts and expertise based on currently available information.