Revisiting COVID-19 Screening after PHE Ends

Revisiting COVID-19 Screening after PHE Ends

It’s time to revisit screening for COVID-19.

Some of you may recall that I recently pointed out that there is no screening during a pandemic. Now that the federal public health emergency (PHE) has ended, how do we code COVID-19 testing? For more official guidance than me, check out the American Hospital Association (AHA)/American Health Information Management Association (AHA/AHIMA) FAQs at Also, Coding Clinic points out that we continue our current practice until Oct. 1, 2023. This marks the beginning of the new fiscal year after the PHE ended.

Let’s review what “screening” really is. The World Health Organization (WHO) defines screening as “the presumptive identification of unrecognized disease in an apparently healthy, asymptomatic population by means of tests, examinations, or other procedures that can be applied rapidly and easily to the target population.” It is the systematic application of a test to identify asymptomatic individuals at potential risk of a specific disorder to warrant further investigation or direct preventative action. There is no known exposure used as a prompt, and the person being screened does not have an expectation that they are at risk of having contracted a disease.

During an epidemic or pandemic, everyone is suspect. Every contact is a potential exposure. COVID-19 testing was done on symptomatic and asymptomatic patients alike to figure out who was infected and potentially contagious. Z20.822, Contact with and (suspected) exposure to COVID-19 was used as the universal diagnosis for medical necessity for testing during the pandemic.

We have now entered the endemic phase. SARS-CoV-2 is likely to cause intermittent infections forever. It will probably be sporadic, and periodically epidemic. “Epidemic” implies that there will be occasional swells of infections, as well as outbreaks in communities and locales. It may be seasonal, like influenza. We are not yet sure what the long-term endemic phase is going to look like.

But COVID-19 testing will need to be performed when indicated. If there is a suspected or known exposure, the rationale for testing will still be Z20.822, or U07.1, COVID-19, depending on whether the result is negative or positive. Z11.52, Encounter for screening for COVID-19, should be reserved for instances when an asymptomatic population is being routinely tested.

Examples of when Z11.52 would be appropriate would be:

  • If a hospital decides they want to retain preoperative testing across the board. Z01.812, encounter for preprocedural laboratory examination would be first-listed diagnosis, and Z11.52 would be a secondary diagnosis.
  • If a nursing home is testing their staff weekly so they can advertise that they are keeping their patients safe, then non-focused testing can be defined as screening. If the same nursing home tests all patients being admitted to their facility upon entry, that is screening, too.
  • If monthly or quarterly random checks are performed somewhere because a public health department is trying to monitor recrudescence of the virus, again, that is screening.

For all of these scenarios, if a specific individual complains of a sore throat and fatigue, and the provider suspects they may actually have COVID-19, Z11.52 is NOT appropriate. The diagnosis for that symptomatic patient should be Z20.822, along with the symptom codes. If the test is positive, Z20.822 is replaced with U07.1, and the symptoms may potentially be subsumed as being integral to COVID-19.

If all the following criteria are met, Z11.52 is appropriate:

  • No local epidemic;
  • Asymptomatic;
  • Routine, pan-testing of all comers; and
  • No known or suspected exposure.

If there is a sporadic epidemic outbreak, you are back to Z20.822 for any testing, because potential exposure is implied. This is consistent with the Official Guidelines (I.C.21.c.1).

You can read my prior article about this topic at but you will need to substitute the correct specific codes. When I wrote that article three years ago, we didn’t have COVID-specific codes yet, so we used the generic codes.

It is said that there are no atheists in foxholes; and there is no screening in pandemics. Now that the pandemic is over, you can start using Z11.52 compliantly after Oct. 1.

Although even I have started venturing out maskless, I am always cognizant that this leaves me at risk of contracting COVID-19 again. Friends, please keep up with your boosters, and stay home if you are sick.

The PHE is over, but COVID-19 isn’t gone.

Programming note: Listen to Dr. Erica Remer live every Tuesday when she cohost Talk Ten Tuesdays with Chuck Buck, 10 Eastern.

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