Physician Pharmaceutical Injectables – Incorrect Procedure Codes and/or Number of Units Billed

The following is reprinted from Medicare Learning Network’s Medicare Quarterly Provider Compliance Newsletter (Volume 1, Issue 1).

Problem Description
CMS uses the RAC program to detect and correct improper payments in the Medicare FFS program and provides information to CMS, ACs, and MACs that could help protect the Medicare Trust Funds by preventing future improper payments. Incorrect coding of pharmaceutical injectables, excessive/ multiple units, Neulasta® (medically unnecessary), vestibular function testing, and duplicate claims were among the most common reasons found for physician overpayments in the June 2008 RAC Demonstration Report.

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Reviews by Demonstration RACs indicated that claims were paid for pharmaceutical injectables with an incorrectly billed number of units; claims paid incorrectly by fee schedule and drugs billed under incorrect HCPCS codes totaled more than $5 million dollars.

Guidance on How Providers Can Avoid These Problems

CMS published MLN Matters® article 6950, which describes injectable drugs, including intravenously administered drugs typically eligible for inclusion under the “incident to” benefit. MM6950 can be reviewed at http://www.cms.gov/MLNMattersArticles/downloads/MM6950.pdf (pdf) on the CMS website.

– Drug coverage is discussed in Chapter 17 of the Medicare Claims Processing Manual (http://www.cms.gov/manuals/downloads/clm104c17.pdf (pdf)), especially Section 40 (Discarded Drugs and Biologicals), Section 70 (Claims Processing Requirements – General), and Section 80 (Claims Processing for Special Drug Categories).

Recommendations

– Be sure staff is aware of the manual chapter and article cited previously regarding Medicare policy on billing for drugs.

– Ensure you adequately document a physician’s drug orders, dosage administered, and when required by CMS policy, the drug dosage wasted amount.

Source: CMS.

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