Health Information Management

Q/A: Billing for wasted drugs

APCs Insider, November 9, 2012

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Q:  A patient comes in for a Herceptin® infusion. The pharmacist mixes the infusion and sends it to us to administer. They document the wastage and bill for the total amount of drug given and amount wasted. This is not for every patient, just the last patient for whom we use the vial.

Our pharmacist just came back from a seminar and thinks we should stop reporting the wasted amount. Our finance department is concerned because the drug is expensive and we would lose that revenue. We thought we could bill for the amount of drugs that we waste. Is this allowed?
 
 
A: The key to billing for the amount of drug that is wasted is based on whether the drug is provided in a single use vial or a multi-use vial.
 
When a drug is provided in a single use vial or other packaging, you should report the amount of drug wasted/discarded and if the drug is separately payable under the OPPS, you will receive payment for the discarded amount.
 
However, this same scenario is not true for drugs provided in multi-use vials or other packaging. Multi-use vials are designed for multiple uses over a period of time, and Medicare coverage does not extend to any amount of the drug discarded from a multi-use vial. CMS provides specific guidance in the Claims Processing Manual, chapter 17, section 40:
 
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.
 
NOTE: Multi-use vials are not subject to payment for discarded amounts of drug or biological.
 
Herceptin (trastuzumab) is supplied in a multi-use vial and contains more than one dose of medication. The medication in the vial is reconstituted and when stored properly, can be utilized over a period of 28 days. Medicare will reimburse only for the amount of drug that is given to each patient. You should not separately report any amount discarded at the end of the viable period.
 
The accurate reporting of units for drugs and biologicals is a hot topic on the OIG’s radar screen. Every facility should audit a sample of claims to insure that the documentation in the record of the drug administered supports the number of units reported. Your pharmacy department can assist with identification of drugs/biological provide in single use vs. multi-use vials.
 
Noridian (NAS) has information specific to Herceptin on its website.
 
Editor’s note: Denise Williams, RN, CPC-H, vice president of revenue integrity services at Health Revenue Assurance Associates, Inc., in Plantation, Fla., answered this question.



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