Health Information Management

FI policies differ in coding Q0081 with chemotherapy

APCs Insider, June 17, 2003

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Reviewing the chemotherapy coding question: A special report on how FI policies differ in coding Q0081 with chemotherapy

Several weeks ago the APCs Weekly Monitor was presented with the following reader question: "Can we code both Q0084 and Q0081 for a patient in our outpatient infusion center with a physician order for a chemotherapy infusion and a leucovorin infusion?"

The answer we provided indicated that it would be appropriate to report both codes and that modifier -59 may be required on the Q0081. Our answer resulted in a number of additional reader questions.

Based on the questions received, we asked two of our experts to conduct some in-depth research on this area. Jugna Shah, MPH and Valerie Rinkle, MPA conducted a review of the official information available in order to provide as comprehensive an answer as possible to the question of charging chemotherapy administration and non-chemotherapy infusion during the same visit.

Shah and Rinkle agree that there is no clear and consistent policy across Medicare fiscal intermediaries (FIs) for coding Q0081 along with the chemotherapy codes Q0083, Q0084, and Q0085.

The answer to whether these services can be reported together has not been addressed in an OPPS related Program Memoranda so it really does come down to what your FI says, if anything on the subject. To add to providers' confusion and frustration is the fact that all FIs do not have a policy related to this topic, and for those that do, sometimes it's a matter of reader or writer interpretation given that the information is unclear.

We set out to look for policies on the following infusion therapy codes:

  • Q0081: Infusion therapy, using other than chemotherapeutic drugs, per visit
  • Q0083: Chemotherapy administration by other than infusion technique only (i.e., subcutaneous, intramuscular, push), per visit
  • Q0084: Chemotherapy administration by infusion technique only, per visit
  • Q0085: Chemotherapy administration by both infusion technique and other techniques (i.e., subcutaneous, intramuscular, push), per visit


The bottom line is that there is no consistent policy or program memorandum that addresses this issue that we are aware of, so the correct answer depends on whether your FI has a policy, and if not, then on the action that you take as a provider.

If your FI does not have a policy, then try to get them to create one by using one of the existing ones as an example.

In the meantime, while you are waiting for them to get back to you, determine if your organization is willing to adopt another FI's policy as interim guidance so that staff know how to charge and bill for these services.

If providers do this, then Shah suggests that they should you document whatever they have you've decided, why they have you've decided it, train your staff, and make sure that everyone implement your interim policy consistently.

A number of providers have used the Kansas FI's policy as a guide for how to report chemotherapy administration along with non-chemotherapy administration as well as injections given that their policy relies on clinical examples and coding scenarios.

At the end of the day, each provider needs to ask the following question in situations like this as well as others where the information seems conflicting or non-existent:

  • Does my FI have a policy?
  • Is it consistent with Medicare and/or other FIs?
  • If my FI does not have a policy, how will we know what to be in compliance with? Are there other policies that we can adopt and use internally?
  • What materials are available to try and resolve the issue with our own FI?
  • Are we prepared to work on this issue with our FI?
  • Are we willing to adopt another policy as our own, even if it's just to have an internal working policy until guidance from our own FI is received?

Shah and Rinkle agree that this issue is far from being resolved given the room for interpretation that still remains. They also believe that national guidance from CMS would go a long way towards ending a lot of the current confusion.

Until there is more concrete information and definitive guidance from Medicare and/or your own FI, providers need to read all Q/As, articles, etc. carefully keeping in mind that what one person says about this topic could be a matter of interpretation.

Our experts have provided their interpretations to give readers a feel for how the same information can be interpreted in different ways. To make your own interpretations, you need valid sources to make the decision that is best for your facility.

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