Health Information Management

New CMS guidance places stiff limit on drug administration code

APCs Insider, February 17, 2006

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New CMS guidance places stiff limit on drug administration code

Hospitals allowed to bill C8952 only once per encounter for same drug

The most controversial drug administration billing/charging/coding question facing hospitals in 2006 is whether they can report multiple units of HCPCS code C8952 (Therapeutic, prophylactic, or diagnostic injection; IV push) when the same drug is administered more than once during a single encounter. In the absence of clear national guidance from CMS, two FIs had released their own guidance allowing hospitals to bill multiple units of C8952 for the same drug.

However, in a new FAQ released by CMS last Friday, the confusion was cleared up: Hospitals can bill multiple units of C8952 only when different substances or drugs are provided in the same encounter. The FAQ states:

Hospitals are to bill for additional IV pushes of different substances or drugs using multiple units of the appropriate push code. This means that hospitals are to bill multiple units of C8952 only when different substances or drugs are provided via intravenous push in the same encounter.

The rationale for this new guidance is based on CPT coding rules for 90775, which do not allow providers to separately report additional pushes of the same substance/drug.

Many providers felt that they could bill C8952 for multiple IV pushes of the same drug during a single patient encounter, says Jugna Shah, MPH, president of Nimitt Consulting in St. Paul, MN, given that the description of C8952 does not contain the "new substance/drug" language of analogous CPT code 90775. She also points to the 2006 OPPS final rule, published in the November 10, 2005, Federal Register, in which CMS states:

  • it would not change 2005 drug payment policies for 2006; and
  • C8952 was created to allow straightforward billing of each push (see pages 68677, 68679 of the final rule).

    Although hospitals finally have clear national guidance on this issue,"there is going to be a financial impact," Shah says, "and depending on the size of your organization and your service mix, it could be significant."

    Run a quick financial impact analysis to measure the effect on your hospital's APC bottom line for 2006. Once the analysis is complete, "take it to your CFO to discuss how your organization might be able to work with others, such as the AHA and HFMA, to get CMS to overturn this decision," says Shah.

    If your FI had released information allowing you to report multiple IV pushes of the same substance/drug given during the same encounter, follow up with them to see whether they are changing their guidance, Shah says. "Regardless, the new guidance comes straight from the top, so even though providers don't like it, they'll have to follow it from a compliance perspective," she says.

    You can read the FAQ at the CMS Web site: http://www.cms.hhs.gov/HospitalOutpatientPPS/Downloads/OPPSGuidance.pdf



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