Health Information Management

Q/A: Reporting drug administration services that cross days

APCs Insider, February 11, 2011

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Q: We noticed that the main section Introduction in 2011 CPT® Manual includes a subsection titled “Time Reporting Issues.” This section addresses a specific example regarding reporting a drug administration service. Within the example, it states that basically the drug administration hierarchy can be reapplied eachcalendar day. Based on this instruction, hospitals can now report two initial services if there are different dates of service or the drug administration services cross calendar days for outpatients. Should hospitals follow this instruction, especially with respect to Medicare outpatient claims submission?

A: We are so glad you asked this question in order to set the story straight. Yes, CPT instructions do provide the example noted in your question. However, in January, CMS issued Transmittal 2130, the 2011 Update of the Hospital Outpatient Prospective Payment System. In the “Billing for Infusions and Injections” section, CMS clarified the Medicare reporting instructions:

“Drug administration services are to be reported with a line item date of service on the day they are provided. In addition, only one initial drug administration service is to be reported per vascular access site per encounter, including during an encounter where observation services span more than 1 calendar day.”

As you can see, CMS has not changed its stance from previous years regarding the reporting of drug administration services. Be sure to follow this billing directive for your hospital’s charge capture and reporting of drug administration services when crossing calendar days on a single UB04 submission.

Editor’s note: Denise Williams, RN, CPC-H, Director of Revenue Integrity Services at Health Revenue Assurance Associates, Inc., in Plantation, FL, answered this question.

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