1. May physicians bill Medicare for off-label uses of chemotherapy drugs.
CMS provides the national guidelines on the unlabeled use for anti-cancer drugs. An off-label usage of a Food and Drug Administration approved drug will be considered for coverage when there are no specific contraindications and one of the following criteria is met:
Its usage is supported by one or more citations in at least one of the three drug compendia listed below, and the usage is not listed as "not indicated" in any of the three compendia:
American Hospital Formulary Service Drug Information
American Medical Association Drug Evaluations
United States Pharmacopoeia Drug Information
The use is supported by clinical research that appears in peer reviewed medical literature. This applies only when an unlabeled use does not appear in any of the compendia or is listed as insufficient data or investigational. Peer reviewed medical literature includes scientific, medical, and pharmaceutical publications in which original manuscripts are published, only after having been critically reviewed for scientific accuracy, validity, and reliability by unbiased independent experts. This does not include in-house publications of pharmaceutical manufacturing companies or abstracts (including meeting abstracts).
2. Can a physician assistant bill a service in the emergency room as 'incident to' an attending group number?
No. For a service to be payable as a physician’s professional service to a hospital patient, i.e., a hospital inpatient or hospital outpatient, the service must be personally furnished to an individual patient by the physician. 'Incident to' services are not allowed in these places of service.
3. Can we collect the co-insurance from our Medicare patients on the date of service when we know the patient does not have co-insurance coverage?
Yes, you may collect the co-insurance on the date of the service from patients who advise you that they do not have co-insurance coverage.
4. How do we bill if both a physician and non-physician practitioner sees the patient in the office during the same encounter?
When an evaluation and management service is a shared/split encounter between a physician and a non-physician practitioner (nurse practitioner, physician assistant, clinical nurse specialist, or clinical nurse midwife), the service is considered to have been performed “incident to” if the requirements for “incident to” are met and the patient is an established patient. If “incident to” requirements are not met for the shared/split E/M service, the service must be billed under the non-physician’s NPI, and payment will be made at the appropriate physician fee schedule payment.”
5. What is the correct procedure code for the administration of the hepatitis B vaccine?
G0010 is the correct HCPCS code to report the administration of hepatitis B vaccine for routine immunization.
6. Can I report procedure code 90471 for the immunization administration of influenza, pneumococcal pneumonia, and hepatitis?
Do not report 90471 for the administration of influenza, pneumococcal pneumonia, and hepatitis. The correct administration codes are:
G0009 (pneumococcal pneumonia)
G0010 (hepatitis B)
7. If a beneficiary receives the influenza and pneumococcal pneumonia vaccinations at the same encounter, must a separate administration procedure code be billed for each vaccine.
Yes, for Medicare purposes, even though you may use the same diagnosis code when a beneficiary receives both vaccinations at the same encounter, report separate administration codes.
8. What must be included in my medical record documentation when administering medication(s)?
Medical record documentation should include the name of the medication, the dosage, and the route of administration. The site of the injection should also be documented as well as any patient reactions to the medication and signature of the person administering the medication. Documentation must be maintained in the patient's chart to support the medical necessity of the injection given. When a portion of the drug is discarded, the medical record must clearly document the amount administered and the amount wasted.
9. Why do claims only reject or deny for one reason and not for everything that is missing or wrong on a claim?
Medicare Part B claims process through the standard Multi-Carrier System. The standard system uses a series of edits and audits to help determine whether claims are eligible for payment. The standard system has been programmed to reject or deny a claim based on the first edit or audit that it does not pass. It does not continue to process against the rest of the edits and audits.
10. What code should physicians report if a HCPCS code couldn't be found for the medication being administered?
You should report charges for all drugs and biologicals using the correct HCPCS codes for the items rendered. It is also important that you make certain the reported units of service for the specific HCPCS code are consistent with the quantity of the drug and/or biological.
In the situation where there is no code to accurately describe the medication being administered, do not use a not otherwise classified (NOC) code based on the HCPCS descriptor. You should only use NOC codes if there is no HCPCS or CPT code available that describes the service performed. These codes should only be used if a more specific code is unavailable. Depending on the medication provided, report J3490 (unclassified drugs), J3590 (unclassified biologics), or J9999 (not otherwise classified, antineoplastic drugs).
11. If auxiliary personnel perform mental health services outside the office setting, e.g., in an institution other than hospital or SNF, we understand their services are covered ‘incident to’ a physician’s service only if there is direct supervision by the physician. Although CMS indicates that a physician in a facility setting cannot provide direct supervision when available by telephone, and being somewhere generally in the facility, we are asking whether a physician (who does not have an office in the facility) who is in the same wing and same floor as the auxiliary personnel, could be viewed as providing direct supervision. Being in the same wing and same floor would be akin to being in an “office suite” such that the physician would be in proximity and able to immediately respond in the event necessary.
12. If the start and stop time is not documented on an infusion, can I bill an IV push?
Since most infusion codes are time-based codes, the start and stop time must be documented to support the time component and to ensure you are billing the most appropriate code. This applies to IV push as well. Remember, each encounter and drug are unique and have different administration rules; some drugs are not billable as an IV push. Therefore, recoding to an IV push may not be appropriate.
13. What date of service should I report when completing a diagnostic interpretation on a different date from the actual test?
We recognize that providers do not always perform the professional component on the same date as the technical component. Many providers prefer to submit a claim with a date of service that reflects the day the professional component was performed, while others prefer to use the day the technical component was performed as the date of service for their professional component.
Information within special edition, SE17023-Guidance on Coding and Billing Date of Service on Professional Claims
, indicates that the technical component is billed on the date the patient had the test performed. When billing a global service, you can submit the professional component with a date of service reflecting when the review and interpretation is completed or the date the technical component was performed.
If you did not perform a global service and instead performed only one component, the date of service for the technical component would be the date the patient received the service; the date of service for the professional component would be the date the review and interpretation is completed.
14. Can I cancel a Part B claim once it is submitted?
15. What is the definition of a rendering physician, a referring physician, and an ordering physician? Where on the claim form is this information reported?
A ‘rendering physician’ is a physician/practitioner who renders/performs medical services. Report the NPI of the rendering physician in block 24J of the CMS 1500 claim form or electronic equivalent.
A ‘referring physician’ is a physician/practitioner who refers patients to another physician or facility for medical services. Report the NPI of the referring physician in blocks 17 and 17B of the CMS 1500 claim form or electronic equivalent.
An ‘ordering physician’ is a physician/practitioner who orders an item or service. Report the NPI of the ordering physician in blocks 17 and 17B of the CMS 1500 claim form or electronic equivalent.
16. Does Novitas require a resubmission reference number when resubmitting a claim?
No, we do not require the resubmission number when resubmitting a claim. If you need to add to the claim for your records please place it in block 19, or the electronic equivalent, of the claim form.
17. How much does modifier 52 adjust RVUs?
We follow CMS guidelines that state: “The fees for services represent the average work effort and practice expenses required to provide a service. For any given procedure code, there could typically be a range of work effort or practice expense required to provide the service. Thus, A/B MACs (B) may increase or decrease the payment for a service only under very unusual circumstances based upon review of medical records and other documentation.”
18. When submitting information with the new Medicare numbers, do you put a dash after the numbers?
No, hyphens/dashes on the Medicare Beneficiary Identifier card are for illustration purposes; don’t include the hyphens/dashes or spaces on transactions.
19. What admin code do we use with Xolair, J2357?
It is up to you to choose the most appropriate administration code to bill with J2357. However, it appears that administration codes 96365-96379 may be appropriate.
20. How do we bill the specimen collection for COVID-19 testing if done in the office?
CMS states practitioners can be paid for assessment and specimen collection for COVID-19 testing using the level 1 evaluation and management CPT code 99211. Considering the public health emergency (PHE), Medicare will recognize this code to be billed for all patients, not just established patients. This approach may help physician practices to operate testing sites during the PHE.
21. Where can I find information on completing a claim form?
22. Can you bill for drug waste if the actual drug was not able to be administered to the patient and cannot be returned to the automated medication dispensing machine? In this situation, no portion of the drug was used.
As described in the Medicare Claims Processing Manual, Pub. 100-04, Chapter 17, Section 40.1
, in addition to paying for the amount of drug that has been administered to a beneficiary, Medicare Part B also pays for the amount of drug that has been discarded, up to the amount that is indicated on the vial or package label. The discarded drug amount is the amount of a single use vial or other single use package that remains after administering
a dose/quantity of the drug to a Medicare beneficiary. Therefore, if no amount of the drug was administered to the patient, then no claim should be submitted.