Oncology & Hematology Coding Alert

Limit wasted drug policy to only single use vials and containers.

The beginning of the New Year marks the dawn of the JW (Drug amount discarded/not administered to any patient) modifier mandate. Medicare has a clear directive on the essential use of the JW modifier on all claims with wasted quantities of drugs. This implies that you will now need to be more vigilant about the amount of drug procured and how much of it was administered to the patient. This calls for clear documentation of the drug administered, the amount wasted and the use of single- or multiple-use vials. Most important, this rule equally applies to all practices.

You can read about this JW mandate in MLN Matters MM9603 (JW Modifier: Drug Amount Discarded/Not Administered to any Patient) which is accessible at: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9603.pdf.

Note the Change for JW Modifier

Historic trends for JW modifier: In the past, the JW modifier was not a mandate. Some Medicare Administrative Contractors (MACs) required providers to report wasted drugs with modifier JW and some did not mandate the modifier.

What is new in 2017? Effective January 1, 2017, all providers, whether in hospitals, freestanding centers or physician offices, will be required to report the JW modifier. Above all, providers will also specifically need to document the amount of discarded drug in the patient’s clinical record. This will be a critical process change for many practices and hospitals where the modifier JW was not required previously. While all providers must document the amount wasted to be paid for that portion of the quantity reported, it must now be reported differently when billed.

Distinguish Single vs. Multiple Use Vials

Medicare instructs the physician to discard any remaining drug whenever the physician administers part of a single-use vial or other single-use package to a Medicare patient. In this case, Medicare pays for the amount that was administered to the patient and the amount that was discarded.

You should remember that this applies only to single-use containers or single-use vials. If your physician discards part of the drug in a multi-use container, remember you may only bill for the amount that was actually administered to the patient.

You can locate the discarded drug policy in section 40 of Chapter 17 in the Medicare Claims Processing Manual.

Learn With an Example

You need to report the drug on the claim in two separate charges. On one claim line, you submit the amount of the drug administered to the patient. You do not need the JW modifier on this line. On another claim line, you submit the amount of drug that was discarded. On this claim line, you append the JW modifier.

Example: You may read that your provider administered 980 mg of bevacizumab to a patient. For this amount of drug, your provider used drug from two single-use vials of 400 mg and two vials of 100 mg.

The HCPCS code for bevacizumab is J9035 (Injection, bevacizumab, 10 mg). You submit 1 unit of J9035 for every 10 mg of bevacizumab.

Your claim for bevacizumab should include:

• J9035 x 98 units for the total amount of drug that was administered to the patient, and
• J9035-JW x 2 units for the 20 mg that was wasted.

Before you proceed to file the claim, make sure that the amount of drug administered and the amount of wasted should equal the total amount of drug billed.

Why bill for wasted drug? This is just a requirement of the process established by CMS. This enables CMS to keep track of how much actually Medicare actually pays for wasted drugs.

Important: CMS states that modifier JW should not be used “if the billing unit is equal to or greater than the total actual dose and the amount discarded.”