Revenue Cycle Insider

Question: I need some help on the issue of pump disconnects. Specifically, what if you have a pump disconnect on Saturday? Can it be direct if there is no physician on site, or does it have to be under general supervision? Also, what if a patient self-disconnects? When and how do you capture the disconnect time? And is your documentation for the connect or disconnect any different for this scenario?

AAPC Forum Participant

Answer: To answer your first question, CPT^® regards 96416 (Chemotherapy administration, intravenous infusion technique; initiation of prolonged chemotherapy infusion (more than 8 hours), requiring use of a portable or implantable pump) as a highly complex procedure that “requires physician or other qualified health care professional work and/or clinical staff monitoring.” This means the service has to be conducted under the “direct supervision for any or all purposes of patient assessment, provision of consent, safety oversight, and intraservice supervision of staff.”

However, that does not mean the physician has to be on site to supervise the procedure. The 2024 Medicare Physician’s Fee Schedule (MPFS) final rule proposed to continue the post COVID-19 public health emergency (PHE) definition of “direct supervision to permit the presence and ‘immediate availability’ of the supervising practitioner through realtime audio and visual interactive telecommunications through December 31, 2024.” So, Medicare allows for audio/visual supervision for services that must be furnished incident-to the physician.

The same is true for G0498 (Chemotherapy administration, intravenous infusion technique; initiation of infusion in the office/clinic setting using office/clinic pump/supplies, with continuation of the infusion in the community setting (e.g., home, domiciliary, rest home or assisted living) using a portable pump provided by the office/clinic, includes follow up office/clinic visit at the conclusion of the infusion) if you are billing for the service that way.

As to your second question, there is no HCPCS Level II or CPT^® code that you can use to bill patient self-disconnects, as the codes are designed to place a value on physician and/or clinical staff work only. Therefore, if the patient merely arrives at the office to return their pump, and the patient has already disconnected, needs no further evaluation and management, and isn’t presenting for refilling or maintenance of the pump for drug delivery, such post-service activity is inclusive of the administration code value.

Bruce Pegg, BA, MA, CPC, CFPC, Managing Editor, AAPC