Health Information Management

Q&A: How do we report antibiotic injections during cataract surgery?

APCs Insider, September 25, 2015

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Q: Our ophthalmologists have begun using injections of antibiotics during cataract surgery rather than the pre-operative eye drops they have used in the past. We always reported the eye drops as a supply based on Medicare guidance.
However, there is a lot more involved in the injection procedures, so we have been reporting them separately with the cataract procedure, as it is not “routine” on all of our cataract procedures—at least not yet. One of our auditors believes this is not a best practice. Is there documentation that supports either method?
A: CMS has guidance that instructs providers how to report these services. It is true that the drug is considered a supply because it is an integral part of the procedure. If the drugs are provided as a combination drug, then the combination is reported with HCPCS code Q9977 (compounded drug, not otherwise classified).
Injections provided during a surgical procedure, regardless of the surgical procedure, are considered an integral part of the procedure and are not separately reportable with a HCPCS code. Any injections provided intraoperatively or in the perioperative periods are included in the HCPCS code reported for the surgical procedure.
There is also guidance that notes that these combinations cannot be reported with HCPCS code C9399 (unclassified drugs or biologicals). An Advanced Beneficiary Notice cannot be given to the beneficiary for these drugs or the injections as they are both covered services, just not separately reimbursed. Providers cannot charge any extra amount beyond the standard copayment for the injections or the drugs because they are part of the ophthalmologic procedure.
Finally, the beneficiaries cannot be asked or instructed to purchase the drugs and bring them to the facility for administration. This guidance applies to physician and facility providers.
The guidance can be located in the CMS Claims Processing Manual, Chapter 17, section 90.2, and Chapter 30, section 40.3.6 and the CY 2015 NCCI Manual, Chapter 8, section D, item 20.
Editor’s note: Denise Williams, RN, CPC-H, seniorvice president of revenue integrity services at Revant Solutions, in Fort Lauderdale, Florida, answered this question.

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