Health Information Management

Develop a consistent policy and procedure for reporting cath lab supplies

APCs Insider, November 11, 2005

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Develop a consistent policy and procedure for reporting cath lab supplies

QUESTION: For diagnostic procedures performed in the catheter lab, should I bundle the diagnostic supplies (i.e., diagnostic catheter, guidewire, and sheath) into the procedure charge? If I do, the device code would not appear on the bill.

Is it appropriate to charge for the diagnostic supplies along with the procedure? I don't understand Medicare's reference to routine supplies.

ANSWER: According to the advice regarding payment determination guidelines as outlined in the Medicare Claims Processing Manual, Pub. 100-04, chapter 25, section 60.4, and UB-92 Editor, you may select either option, but you should separately bill items with a device code or similarly expensive items.

The APC payment limitation includes pharmacy, anesthesia, and supplies that are "incident-to diagnostic services". You may incorporate the "incident-to services" charges as part of the amount for the cardiac cath lab diagnostic procedure charge billed under revenue code (RC) 481, or you may break out the charges and report "incident-to diagnostic supplies" separately from the procedure charges under RC 622. RC 622 is an extension of RC 27X. Bill implants under RC 278 and bill take home surgical dressings separately under RC 623.

The following is generally a good guideline to follow: If the item has a device code, bill it separately. If the item is conditional -- meaning it is not used 100% of the time every time the procedure is performed -- bill the supplies separately. If you don't bill them, CMS can assume the item was included in the procedure. It is unlikely that your facility will be compared apples to apples if you don't bill them. Furthermore, there are various organizations that prepare analyses that could also not make the right assumptions.

If you bill the item separately, report these charges on the same claim as the cardiac cath procedure. Medicare does not accept "late charges" for consideration of payment for "incident-to service" supplies.

If you previously incorporated the charge for "incident-to service" supplies in the procedure charge, you must reduce the charge by the amount of the separately reported supplies. Please note that separately reportable supplies must be patient-specific, single use (disposable) items. These include catheters, guidewires, and sheaths. Make sure to assign the appropriate HCPCS codes. Note these "C" HCPC codes are status indicator N, meaning they are bundled into the APC payment.

Consider as a guide the spreadsheet CMS has listed for procedures that require a device code. Cardiac cath requires the C code to account for the catheter when you perform the procedure. Report the required C code with a charge of a $1.00 as the line item. This strategy allows you to report the C code as required by CMS.

Because this question is somewhat thorny, review other cases where the same situation applies and see what your facility has done in the past. Whichever course you take, be consistent and develop and implement policies and procedures to back up your methods.

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