Corporate Compliance

Reporting bundled services under OPPS, part two

Compliance Monitor, February 25, 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. (Editor's note: This question also produced several responses after appearing in the February 9 Compliance Monitor Q&A. Visit HCPro's Corporate Compliance Web site to read the original question and answer.)

A: I just read the response to the question regarding using active pharmacy HCPCS codes and would like to add a little information.

First, there were 50 medications with active HCPCS codes in 2004 that did not receive separate reimbursement, but will in 2005. I wrote an article on this topic for the February HCCA Compliance Today magazine. Having the active codes in the CDM would ensure payment whenever CMS makes changes.

Second, in Change Request 3632, released January 6 and discussed in Medlearn Matters number MM3632, CMS states:

"Hospitals are strongly encouraged to report charges for all drugs, biological, and radiopharmaceutical, regardless of whether the items are paid separately or packaged, using the correct HCPCS codes for the items used.

"It is also of great importance that hospitals billing for these products make certain that the reported unit of service is consistent with the quantity of drug, biological, or radiopharmaceutical that was actually administered to the patient."

This question was answered by Deborah Sheets, RN, Navigant Consulting, Inc--Healthcare., Atlanta.

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