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Q/A: Charging for drug administration in ED by nurse

APCs Insider, October 8, 2010

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Q: A patient comes into the ED and the nurse administers drugs as an injection or IV. Do we charge an administration fee for this? Would the nurse need to document a start and stop time? Or would it be a specific charge determined by what the drug is and how it is administered? Would the charge be a part of the drug charge itself? I want to make sure we are charging this appropriately to Medicare. 

If Medicare does pay for an administration fee, how much would it pay in a percentage figure?

A: Medicare recognizes the drug administration codes in the CPT® manual and hospitals should use them in accordance with their definitions and the documentation for the services they render. Because drug administration codes are time-based codes, the nurse or the physician must document information to support the code reported. Depending on other services rendered during the same encounter, payers sometime consider drug administration services as an integral part of the other service. For example, the administration of pain medication following a procedure is an integral part of that procedure and not separately reportable. You must follow these coding rules when assigning codes for an encounter.

If the drug administration is considered integral to another service such that it cannot be coded separately, the charge representing the cost of the services should be reflected on the claim. This can be accomplished by either including the cost/charge in the other service, or by reporting a separate line without the drug administration HCPCS code. Not reporting the HCPCS code ensures that the charge/cost is reflected for future rate-setting but no separate payment is received for a service that is paid as part of another service.

For the episode you mention, if a covered drug is administered, the facility would charge for the drug and its administration as long as the documentation in the record supports the service provided. Medicare reimbursement is based on the APC for hospitals subject to OPPS; for facilities not subject to APC reimbursement, the usual payment methodology would hold.

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