Q&A: Postop pain/nausea medication, antibiotics generally not separately billable

Q:  Is it appropriate to bill for postop pain/nausea medications and antibiotics administration in a hospital setting?  

I’ve been advised to continue to bill these services to Medicare using revenue code 710 and no CPT/HCPCS code. Is this practice appropriate, or will OCE edits prevent billing of these services because Medicare considers them inherent to the procedure?

A: In general, payment for the outpatient procedure includes post procedure recovery services and associated pain management treatments. The OCE typically edits for items that are included in or inherent to another procedure using the NCCI edits which use CPT/HCPCS codes for editing purposes. Removing the CPT/HCPCS code will allow the service to pass NCCI edits for drug administration. However, the question of whether it is appropriate to continue to bill this on a separate line is not answered by the OCE editing of the claim. 

CMS has not spoken directly on the issue of how to bill postop pain or other injections. However in 2006, CMS posted a Q&A document clarifying the appropriateness of billing separately for other “included services” in the drug administration setting. CMS states the following:

Visit the CMS Web site for more information.

This appears to indicate that it is appropriate to include the charges for these postop injections either in the procedure they are associated with or on a separate line without a HCPCS code in an appropriate revenue code center. Revenue code 0710 for recovery room would be appropriate when the service was provided in that department. Note that if a problem unrelated to the surgery, anesthesia, or pain management occurs and requires administration of IVs and injections, you may bill for them separately as long as documentation supports a separate charge for this service. You should bill these under an appropriate revenue code center that will cause the charges to be paired with the cost center that reflects the expenses (i.e., nursing time).

(The above Q&A was adapted from the July issue of APC Answer Letter.)