Policy
Pharmacy Practice News • February 2022
17
Reimbursement Matters
2022 Payment Updates
COVID-19 Vaccine and mAbs: Billing for Part A A
n often-neglected revenue source are the fees that are available for adminisering an injectable medication or biologic, regardless of whether it was purchased by the provider or obtained at zero cost. If this is unfamiliar territory for you, it’s covered in Module 5 of our Reimbursement Tool Kit (bit.ly/3rS8xI7). The newly announced ability to bill for the administration of monoclonal antibody (mAb) infusions is a perfect example of how to tap into this underappreciated revenue source—injectable drug administration in the outpatient setting. A recent article by Novitas Solutions (bit.ly/3KCTGdx) offers useful guidance on how to bill for administering mAbs and COVID-19 vaccines. According to this MAC, beneficiary coinsurance and deductibles for the mAbs will be waived. When COVID-19 vaccine and mAb doses are provided by the government without charge, be sure to only bill for the administration, with the billed amount at $0.01, or whatever minimum charge your billing system allows. The authors also say that if the patient
compliance with recommendations for filter use with PN administration. • Although 1.2-micron filters are not recommended for use as a routine infection control measure, these devices are effective in preventing Candida albicans, a pathogen frequently associated with PN administration, from reaching the patient. • ASPEN recommends that healthcare organizations that do not filter PN admixtures or ILE reevaluate these decisions and consider the small price of filters compared with increased morbidity and mortality that may result from not filtering ILEs or PN.
References 1.
Cohen MR, Smetzer JL. Selected medication safety risks to manage in 2016– Part I intravenous fat emulsion needs a filter. Hosp Pharm. 2016;51(5):353-357.
2. Lumpkin MM. Safety alert: hazards of precipitation associated with parenteral nutrition. Am J Hosp Pharm. 1994;51(11):1427-1428. 3. Wilmore DW, Dudrick SJ. An in-line filter for intravenous solutions. Arch Surg. 1969;99(4):462-463. 4. O’Grady N, Dellinger EP, Gerberding JL, et al. Guidelines for the prevention of intravascular-catheter related infections. MMWR Recomm Rep. 2002;51(RR-10):1-29. 5. Ball PA. Intravenous in-line filters: filtering the evidence. Curr Opin Clin Nutr Metab Care. 2003;6(3):319-325. 6. Oie S, Kamiya A. Particulate and microbial contamination in in-use admixed
was enrolled in a Medicare Advantage plan in 2020 and 2021, submit the infusion claims to original Medicare, effective Jan. 1, 2022. CMS also offers a useful guidance at go.cms.gov/3C9lzF5.
Keep a Handle on Bundled Payments Here are a few more basics to keep in mind when billing for injectable drugs in the outpatient setting. Although under OPPS, reimbursement for the drug products may be decreasing or be
incorporated into a bundled or packaged payment or even be provided free of charge, payments for injectable drug administration. These new rulings on mAb administration bring the importance of understanding this revenue source to light. Private insurers may offer these add-on payments, too. The CMS definition of ”drug administration,” for the purposes of reimbursement, is a bundle that involves both nursing and pharmacy, and includes: • use of local anesthesia; • starting the IV; • access to IV, catheter or port; • routine tubing, syringe and supplies; • drug preparation; • flushing at completion; and • hydration fluid. To recoup these charges, there must be a well-oiled mechanism for capturing the data related to drug administration, with the requisite charting being done to substantiate the charges. Mechanisms for billing drug administration fees for zero-priced drugs need to be a priority.
“Reimbursement Matters” is a tool for maintaining your health system’s fiscal health. Please email the author at bonniekirschenbaum@ gmail.com with suggestions on reimbursement issues that you would like to see covered.
Bonnie Kirschenbaum, MS, FASHP, FCSHP
Revenue cycle functions and IT systems must be built to support this billing. What are the quirks of your computerized billing system? You may need to price the product at anywhere between $0.01 and $1.01 to prevent the system from automatically throwing out the charge. Remember, if drug data are missing, payors will assume that no drug was administered—and that, of course, means no payment. The entire flow of medication order processing from a reimbursement perspective is shown in the Figure. see mAb BILLING, page 23
parenteral nutrition solutions. Biol Pharm Bull. 2005;28(12):2268-2270. 7. Puntis JW, Wilkins KM, Ball PA, et al. Hazards of parenteral treatment: do particles count? Arch Dis Child. 1992;67(12):1475-1477.
INNOVATION IN
8. Hill SE, Heldman LS, Goo ED, et al. Fatal microvascular pulmonary emboli from precipitation of a total nutrient admixture solution. JPEN J Parenter Enteral Nutr. 1996;20(1):81-87.
SECURE DRUG DELIVERY PREP-LOCK™ TAMPER EVIDENT CAPS
9. Mirtallo J, Canada T, Johnson D, et al. Safe practices for parenteral nutrition. JPEN J Parenter Enteral Nutr. 2004;28(6):S39-S70
Help ensure the safe delivery of your compounds, comply with growing regulations, and enhance patient care.
10. Worthington P, Gura KM, Kraft MD, et al. Update on the use of filters for parenteral nutrition: an ASPEN position paper. Nutr Clin Pract. 2021;36(1):29-39. 11. Christensen ML, Ayers P, Boullata JI, et al. Lipid injectable emulsion survey with gap analysis. Nutr Clin Pract. 2017;32(5):694-702.
Strengthen <797> compliance
Ensure the integrity of your compounds with Prep-Lock™ Tamper Evident Caps.
12. Woodhouse CR. Infusion thrombophlebitis: the histological and clinical features. Ann R Coll Surg Engl. 1980;62(5):364-368. 13. Van Boxtel T, Pittiruti M, Arkema A, et al. WoCoVA consensus on the clinical use of in-line filtration during intravenous infusions: current evidence and recommendations for future research. J Vasc Access. 2021 Jan 28. doi:10.1177/1129729821989165
Maintain Sterility
Evidence of access indicates the potential compromise of content sterility.
14. Perez M, Decaudin B, Abou Chahla W, et al. Effectiveness of in-line filters to completely remove particulate contamination during a pediatric multidrug infusion protocol. Sci Rep. 2018;8(1):7714.
Mitigate Diversion
Serves as an active deterrent to potential diversion and misuse.
Additional Resources •
ASPEN Parenteral Nutrition Resources: https://www.nutritioncare.org/ PNResources/
•
ASPEN Update on the Use of Filters for Parenteral Nutrition: nutritioncare.org/ pnfilters
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