Q&A: Report separately payable drugs under revenue code 0636

QUESTION: Should we report all injectable drugs (i.e., J0000 -- J9999) under revenue code 0636 instead of revenue code 0250?

ANSWER: Under the OPPS, you must report separately payable drugs (HCPCS Level 1 and II codes) using revenue code 0636. CMS continues to provide information regarding how hospitals should bill separately payable drugs. For example, Transmittal 1487, April 2008 OPPS update states the following:

Hospitals and providers are reminded to ensure that units of drugs administered to patients are accurately reported in terms of the dosage specified in the full HCPCS code descriptor. That is, units should be reported in multiples of the units included in the HCPCS descriptor. For example, if the description for the drug code is 6 mg, and 6 mg of the drug was administered to the patient, the units billed should be 1. As another example, if the description for the drug code is 50 mg but 200 mg of the drug was administered to the patient, the units billed should be 4. Providers and hospitals should not bill the units based on the way the drug is packaged, stored, or stocked. That is, if the HCPCS descriptor for the drug code specifies 1 mg and a 10 mg vial of the drug was administered to the patient, bill 10 units, even though only 1 vial was administered. HCPCS short descriptors are limited to 28 characters, including spaces, so short descriptors do not always capture the complete description of the drug. Therefore, before submitting Medicare claims for drugs and biologicals, it is extremely important to review the complete long descriptors for the applicable HCPCS codes.

You may report packaged drugs or drugs that have a status indicator N HCPCS code under revenue code 025X. Also report revenue code 025X for drugs with no HCPCS code. Each facility must assess their billing system's capabilities for reporting HCPCS codes under revenue code 025X. If you don’t have this capability, bill these drugs under revenue code 0636 (drugs requiring detailed coding).

CMS encourages hospitals to report packaged drugs with a HCPCS code. However, this is not currently a requirement. Facilities should make an internal decision how to report packaged drugs, with or without HCPCS, based on their payer mix and financial analysis.