Corporate Compliance

Reporting bundled services under OPPS

Compliance Monitor, February 10, 2005

Q: If a drug has a HCPCS code and it's a bundled service, does CMS expect or require us to report the HCPCS codes on our claims? If so, do the units reported need to be correct, even though we won't receive payment? We're trying to determine whether we can remove the codes from the CDM for these nonpaid drugs.

A: A cardinal rule of reporting codes under OPPS is to capture all resources expended in providing medical care to a patient, aside from bundled supplies and other services associated with the medical care of the patient.

A major reason for reporting these items (e.g., drugs that are represented by specific HCPCS codes but are not separately payable) is to capture and report the true costs associated with patient treatment. Remember that CMS uses historic data to establish future reimbursement rates under OPPS.

If CMS determines in future years that a service warrants receiving separate reimbursement, it will use the HCPCS codes billed in past years to determine the weight and rate for the service. If you choose not to use the HCPCS because you won't receive reimbursement, this may hamper your payment in future years.

It generally benefits the provider to accurately capture and report items such as drugs that are not separately payable. Accurately capturing and reporting of drugs entails reporting the drug or drugs used, including the correct number of corresponding units administered. To do otherwise is not doing justice to the reporting of costs and charges and could negatively affect future reimbursement of APC amounts.

This question was answered by Glenn Krauss, RHIA, CCS, an independent consultant in Maryville, TN.

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