Health Information Management

Q/A: Single vial used for multiple patients

APCs Insider, May 13, 2011

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Q: Our pharmacists say they are allowed to use a single vial for more than one patient, as long as it is within a certain period of time (a few hours I think). Have you heard of this practice before? Our pharmacist opened a single vial containing 300mg of a drug. Patient A received 100mg; Patient B received 75mg; and Patient C received 100mg. We wasted the remaining 25mg. We want to charge each of them 100mg.

A: Pharmacists can use a single vial for several patients, and actually, CMS expects providers to schedule patients in a way to maximize the use of the drug and minimize the waste. The wastage would be reported on the last patient that received the drug – in your example, this would be patient C.  The citation is in the Medicare Claims Processing Manual, chapter 17, section 40:

40 - Discarded Drugs and Biologicals
(Rev. 1962, Issued: 04-30-10, Effective: 07-30-10, Implementation: 07-30-10)
The CMS encourages physicians, hospitals and other providers and suppliers to care for and administer to patients in such a way that they can use drugs or biologicals most efficiently, in a clinically appropriate manner. When a physician, hospital or other provider or supplier must discard the remainder of a single use vial or other single use package after administering a dose/quantity of the drug or biological to a Medicare patient, the program provides payment for the amount of drug or biological discarded as well as the dose administered, up to the amount of the drug or biological as indicated on the vial or package label.

CMS cited several examples in Transmittal 1478 including: 

A provider schedules three Medicare patients to receive Botulinum Toxin Type A on the same day within the designated shelf life of the product. Currently, Botox is available only in a 100-unit size. Once Botox is reconstituted, it has a shelf life of only four hours. Often, a patient receives less than a 100 unit dose. The provider administers 30 units to each of the three patients. The remaining 10 units that must be discarded are billed to Medicare on the account of the last patient. Therefore, 30 units are billed on behalf of the first patient seen and 30 units are billed on behalf of the second patient seen. Forty units are billed on behalf of the last patient seen because the provider had to discard 10 units at that point.

Editor’s note: Andrea Clark, RHIA, CCS, CPCH, president of Health Revenue Assurance Associates, Inc., in Plantation, FL, answered this question.

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