Health Information Management

FI policies differ in coding Q0081

APCs Insider, June 27, 2003

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June 13, 2003
Vol. 4, No. 23


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Keith Siddel,
MBA, PhD (c),
president, CEO
HRM, Hospital Resource Management

Cheryl D'Amato,
director health information management
HSS, Inc.

Julie Downey,
ambulatory coding coordinator, HIM
University Colorado Hospital

Carole Gammarino,

Julia R. Palmer
Health Information Management Division of HRM

Valerie Rinkle, MPA,
revenue cycle director
Asante Health System




New PM clarifies DSMT supervision rules and other "incident to" requirements

PM B-03-043, issued May 23, 2003, clearly states that "incident to" supervision rules and other "incident to" requirements do not apply to Diabetes Outpatient Self-Management Training (DSMT) services.

CMS first implemented this provision in 2001, published in 42 CFR 410.140-146. This new PM is CMS's response to Medicare contractors and providers who have been asking for clarification on whether supervision and other "incident to" requirements must be met when billing for DSMT services.

The codes used for this service are:

  • G0108-Diabetes outpatient self-management training services, individual, per 30 minutes.
  • G0109-Diabetes outpatient self-management training services, group session (2 or more), per 30 minutes.
For more information on the PM B-03-043, check out CMS Central on

Reviewing the chemotherapy coding question: A special report written by APC experts Jugna Shah, MPH, and Valerie Rinkle, MPA.

Click Special Report for an in-depth discussion of how FI policies differ in coding Q0081 with chemotherapy


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TODAY'S TOPIC: To bill or not to bill? Pass injection fees on to patient

Question: There are a small number of injectable medications that CMS has indicated should be considered self-administered drugs. They are assigned a revenue code 637 and are submitted on a separate non-covered claim. Is it appropriate to bill an injection charge for these medications? Can this charge be billed to Medicare or the patient?

Answer: CMS has instructed providers to bill, in addition to the medication, an injection charge which covers the cost of providing the medication to the patient.

In the case of self-administered medications, CMS has indicated that the patient is liable for the cost of the medication and the Medicare program considers them non-covered. If the cost of the medication is non-covered, then the administration fee is non-covered as well.

To answer the question of whether to bill this administration fee to the patient, first determine whether the charge for self-administered medications is being billed to the patient. If these items are billed and collected from the patient,it would be reasonable to also bill the injection fee to the patient.

Although an Advance Beneficiary Notice (ABN) is not required in this instance, we recommend providers get one, since this is a benefit category denial and not a denial based on medical necessity. Patients are likely to question this practice if not informed ahead of time, and an ABN gives the provider an opportunity to prepare the patient for the financial liability.

ASK THE EXPERT: Do you know anything about a new CPT code that allows a physician to bill a hospital for mandated on-call service? Click here to find out!

PAY PER VIEW: Find coders through conventional and unconventional methods

The nationwide coder shortage shows no signs of easing up, so recruiting skills are more important than ever. During his presentation at the American Academy of Professional Coders' recent 11th annual conference in Honolulu, J. Eric Sandham, CHC, CPC, compliance educator for Central California Faculty Medical Group in Fresno, offered his suggestions.

Read more here.

The cost is $10. Briefings on Coding Compliance Strategies subscribers have free access via their online subscriptions.

Coding and Compliance Feature Article of the Month: Interventional procedures cause coding confusion

Questions from readers are answered by a team of experts working in the APC area within the health care industry. Their answers are provided as advice. Readers should consult the federal regulations governing OPPS, related CMS sources, and with their local fiscal intermediary before making any decisions regarding the application of OPPS to their particular situations.


There's one thing you can count on in the world of OPPS and APCS: The rules keep changing.

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