Health Information Management

Q/A: Billing for self-administered drugs

APCs Insider, December 4, 2009

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Q: Is billing all self-administered drug (SAD) charges as integral to a procedure using revenue code 250 inappropriate? Or should we bill SADs to patients using revenue code 637? Is this the hospital’s choice?
A: CMS considers some drugs so integral to a procedure or treatment that they are packaged into the APC as supplies for the procedure or treatment. Therefore, they are covered as part of that procedure or treatment. CMS addresses this topic in Transmittal A-02-129. Facilities should report integral drugs treated as packaged supplies under the revenue code associated with the cost center under which the hospital accumulates the cost of drugs, according to CMS. This is presumably the pharmacy series of revenue codes. It is not provider choice. If a drug is truly integral to a procedure as defined in Transmittal A-02-129, providers should report it as such. However, this decision must occur on a case-by-case, item-by-item, scenario-by-scenario basis.
By definition, eye drops are considered self-administered as defined in the Medicare Benefit Policy Manual. However, specific drops are administered as an integral part of a cataract surgery procedure and therefore are considered a covered item for this procedure. Report these drops with revenue code 250, not 637. Report the drops with revenue code 637 if prescribed for a condition not related to a cataract surgery.
Oral pain medications are SADs, even when administered post-operatively to control pain related to a surgical procedure. Providers should thoroughly review guidance from their FI/MAC because of varying interpretations regarding whether an injectable drug is a SAD. One FI/MAC considers insulin self-administered regardless of the route of administration; others consider insulin self-administered unless administered intravenously.
Providers should proceed with caution before assigning revenue code 250 to a SAD. SADs are statutorily excluded pursuant to Medicare law, so there is a fine line.

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