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ICD-10-CM Coding Update: Post COVID-19 Conditions

In (FY) 2022, we saw an update from the CMS and NCHS to the International Classification of Diseases, 10th revision, clinical modification (ICD-10-CM), which included a code addition for post-COVID conditions. In this month’s Forensic AI Alert, we will look at the proper use of code U09.9, post-COVID conditions, unspecified. This code may be found in Chapter 22 of the ICD-10CM code book: Codes for Special Purposes (U00-U85). 

According to the Centers for Disease Control and Prevention (CDC), post-COVID conditions “are a wide range of new, returning, or ongoing health problems people can experience four or more weeks after first being infected with the virus that causes COVID-19.” Post-COVID conditions, also known as long COVID, long-haul COVID, post-acute COVID-19, long-term effects of COVID, chronic COVID, and post-acute sequelae of SARS-COV2 infection (PASC), can have “different types and combinations of health problems for different lengths of time.” 

The most reported signs and symptoms, including varying combinations, are:

    • Dyspnea, shortness of breath, cough 
    • Fatigue or tiredness 
    • Difficulty thinking or concentrating (brain fog) 
    • Dizziness or lightheadedness on standing 
    • Headache 
    • Chest or abdominal pain 
    • Palpitations, tachycardia 
    • Joint or muscle pain 
    • Numbness 
    • Diarrhea 
    • Sleep problems 
    • Fever 
    • Rash 
    • Mood changes 
    • Change in smell or taste 
    • Changes in menstrual cycle 
    • Worsening of symptoms following minor physical or mental exertion (post-exertional malaise) 

In the 2022 ICD-10-CM guidelines, a new section, I.C.1.g.1.m., specifies that for sequelae of COVID-19 or associated symptoms or conditions that develop following a previous COVID-19 infection, assign codes for specific symptoms or conditions related to the prior COVID-19 infection and code U09.9. This means you will report U09.9 instead of B94.8, sequelae of other and unspecified infectious and parasitic disease. ICD-10-CM also added a “code first” note under U09.9 that instructs coders to list first the code for the specific condition related to COVID-19, such as chronic respiratory failure (J96.1), loss of smell or taste (R43.8), or multisystem inflammatory syndrome (M35.81). Therefore, U09.9 is intended to be used as a secondary diagnosis code.  

One clarification in the same section of guidelines states U09.9 should not be reported for coding manifestations of active COVID-19 infections. However, if a patient has a condition associated with a previous COVID-19 infection AND develops a new, active (current) COVID-19 infection, U09.9 may be assigned in addition to U07.1, COVID-19, to identify both the current infection and the conditions related to a previous COVID-19 infection.  

If the patient has a history of COVID-19 without an active related condition, it would be appropriate to assign code Z86.16, personal history of COVID-19. You will also note code Z86.16 excludes code U09.9, so the two codes should never be reported together.  

Examples of the correct use of U09.9: 

Example A:  Patient is in the hospital with multisystem inflammatory syndrome related to a previous COVID-19 infection. The patient has a history of COVID-19 infection 3 months ago but is not currently infected.  


    • M35.81, multisystem inflammatory syndrome 
    • U09.9, post-COVID conditions, unspecified 

 Example B:  Patient is in the hospital with re-infection with COVID-19 and COVID pneumonia.  Patient also has COVID-19 related multisystem inflammatory syndrome from a previous infection. 


    • U07.1, COVID-19 
    • J12.82, COVID pneumonia 
    • M35.81, multisystem inflammatory syndrome 
    • U09.9, post-COVID conditions, unspecified 

Note:  As of July 1, 2021, “long-COVID” also known as post-COVID conditions, can be considered a disability under the Americans with Disabilities Act (ADA). 

Things to monitor: 
    • Continued utilization of B94.8 in lieu of the new U09.9 will result in a higher MS-DRG payment. 
    • Some of these patients with U09.9 may require many additional supportive services post discharge such as:  
        • Physical Rehabilitation Stays 
        • Nursing Home Care 
        • DME, including one or more of the of following: walkers, wheelchairs, oxygen 
        • Home Health Services 
        • Outpatient Physical therapy or Occupational therapy 
        • These patients may require monitoring from a pulmonology and cardiac standpoint depending on the severity of their illness 
  1. 2022 ICD-10-CM Official Guidelines for Coding and Reporting,
    1. Centers for Disease Control and Prevention (CDC), July 9, 2021, Post-COVID Conditions: Overview, 
      1. Centers for Disease Control and Prevention (CDC), July 12, 2021, Long-Term Effects, 
        1. U.S. Department of Health and Human Services, Guidance on “Long COVID” as a Disability Under the ADA, Section 504, and Section 1557, 
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