Neurology & Pain Management Coding Alert

In a policy revision effective July 1, Medicare amended its manual regarding single-use vials and packages of drugs and biologicals.

The changes apply to Chapter 17 of the Medicare Claims Processing Manual, Sections 40 and 100.2.9.

- Section 40 clarifies that carriers will cover the amount of a single vial or single-use package of a drug or biological that the practitioner discarded along with the amount administered to the Medicare patient.

- Section 100.2.9 outlines qualifications the provider must meet before receiving reimbursement for the amounts administered and the amounts discarded. Your practitioner must show a "good faith effort" in minimizing the portion of unused drug or biological by scheduling patients so they can share vials and by ordering and storing the drug responsibly. Your practitioner should also show that he has attempted to minimize the unused portion of drug or biological.

Caution: The policy change affects single-use vials, not multi-use vials. You still cannot receive reimbursement for discarded amounts of drugs or biologicals from multi-use vials.

Read it all: You can see CR5520, the official instructions to Medicare contractors, by visiting the CMS Web site. Log on to http://www.cms.hhs.gov/Transmittals/ downloads/R1248CP.pdf.

Example: Your neurologist schedules three patients in back-to-back appointments for chemodenervation (64612, Chemodenervation of muscle[s]; muscle[s] innervated by facial nerve [e.g., for blepharospasm, hemifacial spasm]; 64613, - neck muscle[s] [e.g., for spasmodic torticollis, spasmodic dysphonia]; or 64614, - extremity[s] and/or trunk muscle[s] [e.g., for dystonia, cerebral palsy, multiple sclerosis]) with Botulinum A. He ordered and has available four vials of Botulinum A (100 units each) for the procedures:

- Patient A receives 175 units of Botulinum A; you report J0585 (Botulinum toxin type A, per unit) with 175 units.

- Patient B receives 120 units of Botulinum A; you report J0585 with 120 units.

- Patient C receives 75 units of Botulinum A, and the provider has unavoidable wastage of 30 units. He documents this wastage in a note for Patient C, and you report J0585 with 105 units.

Checkpoint: The key lies in noting the unavoidable wastage of Botulinum so every unit is accounted for. You can split the vials and bill for the exact units given.

If your provider has "leftover" after the last patient, you bill for all units and document the number of units that had to be wasted (or discarded) on the final or last patient.