Question: Please advise me if a hospital-based practice can bill an injection code 90782 (Therapeutic, prophylactic or diagnostic injection] specify material injected]; subcutaneous or intramuscular) or 90784 ( intravenous) on the same day as a physician visit, providing the physician was able to bill an E/M charge that day. Also, can a hospital-based clinic charge 96530 (Refilling and maintenance of implantable pump or reservoir for drug delivery, systemic [e.g., intravenous, intra-arterial]) if we use Q codes? New Mexico Subscriber Answer: The physician cannot bill for the procedures performed by ancillary staff who are not employed or contracted by her. If the injections are performed in a hospital-based clinic, by the physician's staff in this case, the physician is paying rent to the hospital for the space then the E/M code with modifier -25 (Significant, separately identifiable E/M service by the same physician on the same day of the procedure or other service) as well as the injection can be billed to non-Medicare patients. Medicare rolls the injection into the E/M. The second and more typical scenario is when the physician is practicing in the hospital clinic and the supportive staff (RNs, LPNs, etc.) is employed by the hospital. In this case, the physician can bill for his services but not for the services performed by the hospital staff such as injections. These charges are billed by the hospital using the appropriate APC codes and associated CPT or Q codes. The hospital also bills for chemotherapy using Q codes, and many other procedures are billed using CPT codes.
Likewise, the practice can also bill for 96530 if the practice is established as described.