Corporate Compliance

Billing incident to cardiac cath supplies

Compliance Monitor, November 4, 2005

Q. For diagnostic procedures in the cath lab, do I bundle the diagnostic supplies (e.g. diagnostic catheter, guidewire and sheath) into the procedure charge? If I do, the device code would not appear for it would not be billed.


Is it appropriate to charge for the diagnostic supplies along with the procedure? I'm not sure what Medicare's definition of routine supplies is referring to.


A. According to the advice regarding payment determination guidelines outlined in the Medicare Claims Processing Manual, Pub. 100-04, chapter 25, section 60.4 and UB-92 Editor, either option may be selected but items with a device code or similarly expensive items should be billed separately.


The APC payment limitation includes pharmacy, anesthesia, and supplies "incident to diagnostic services." Providers may incorporate the "incident to services" charges as part of the amount for the cardiac cath lab diagnostic procedure charge billed under revenue code (RC) 481 or the provider may "break out" the charges and report "incident to diagnostic supplies" separately from the procedure charges under RC 622 which is an extension of RC 27X. Implants are billed under RC 278 and take home surgical dressings are separately billed under RC 623.


Generally, a good rule of thumb is if the item has a device code, it must be billed separately. Secondly, if the item is conditional, meaning the item is not 100% used in every performance of the procedure, then it should be billed separately. That's because CMS can assume, if you don't bill them, than they must be included. It is unlikely that your facility will be compared apples to apples if you don't bill them. Furthermore, there are various organizations which prepare analyses which could also not make the right assumptions.


If billed separately, these charges must be reported on the same claim as the cardiac cath procedure. Medicare does not accept "late charges" for consideration of payment for "incident to service" supplies.


If the provider has previously incorporated the charge for "incident to service" supplies in the procedure charge, the charge must be reduced by the amount of the supplies to be reported separately. Please note that separately reportable supplies must be patient-specific, single use (disposable) items. These include catheters, guidewires, and sheaths. Assign also all appropriate HCPCS codes. Note these "C" HCPC codes are status indicator N (bundled into the APC payment).


Consider following the spreadsheet CMS has listed for procedures that require a device code. Cardiac cath requires the C code for the catheter when doing the procedure. Report the required C code with a charge of a $1.00 as the line item. This way, you can report the C code CMS required.


Because this question is somewhat thorny, review other cases where the same situation would apply and see what your facility as been doing. Whichever course you take, you need to be consistent and develop policies and procedures to back up your actions.


This answer was provided by Sara Wolf, CCS, coding manager for LBMC Healthcare Group in Brentwood, TN., and by the editorial advisory board of APCs Weekly Monitor.


Most Popular