Oncology & Hematology Coding Alert

Coders at hospital outpatient cancer treatment facilities should use only Q codes when billing Medicare for chemotherapy administration, which means billing by the visit instead of by the length of the chemotherapy treatment accounted for in the CPT manual. Billing specialists at these facilities also must resist the temptation to use multiple Q codes for a single procedure to account for a lengthy administration of chemotherapy drugs, says Margaret Hickey, MS, MSN, RN, OCN, CORLN, an independent coding consultant and former clinical director at the Tulane Cancer Institute in New Orleans.

The change in coding procedure is part of the Health Care Financing Administrations (HCFA) sweeping new rules that classify payment for hospital outpatient procedures into groups similar to diagnostic-related groups for inpatient procedures. Called ambulatory payment classifications (APC), the new payment methodology was implemented Aug. 1.

With APC, facilities providing outpatient oncology services no longer will be allowed to choose chemotherapy administration codes (96400-96549) based on the length of the chemotherapy administration. Before APC, for example, hospital outpatient departments billed for chemotherapy administration using 96410 (infusion technique, up to one hour) and 96412 (infusion technique, one to 8 hours, each additional hour [list separately in addition to code for primary procedure]). Now, the same scenario would be billed with Q0084 for a single chemotherapy infusion visit because the outpatient department must choose the chemotherapy code based on the method of administration. The range of Q codes, which are used as temporary codes until Medicare assigns permanent codes, includes:

Q0083 Chemotherapy administration by other than
infusion technique only (e.g., subcutaneous, intramuscular, push), per visit;

Q0084 Chemotherapy administration by infusion
technique only, per visit; and

Q0085 Chemotherapy administration by both
infusion technique and other technique(s)(e.g., subcutaneous, intramuscular, push), per visit.

These facilities will realize quickly that the potential to lose money or earn more money depends on the length of chemotherapy administration they typically bill for. The payment for each Q code represents what HCFA describes as an average of past payments for each type of chemotherapy administration.

For facilities that must follow lengthy research protocols, such as academic hospitals, the average payment represents less money than the facility has received using CPT codes. By contrast, outpatient departments that provide shorter chemotherapy administration will get paid more using APC codes.

Some facilities already have noticed the inequity, and coders are questioning what to do when the Q codes fall short of paying for the cost of longer chemotherapy administration. Some coders have suggested using a Q code more than once to account for longer chemotherapy services.

Thats an inclination for some, says Hickey. But you cant use multiple Q codes for a single procedure.
Infusion, injection and transfusion services can be billed on the same day and as multiples without reduction in payment. But, Hickey says, to bill correctly as multiples, each code must be accompanied by the proper chemotherapy drug code to show each Q code represents a separate procedure.

Hospitals should replace CPT codes 96400-96549 with Q0083-Q0085 in their charge masters. Failing to do so will result in billing systems not automatically identifying the proper APC because the new payment system does not recognize chemotherapy admission codes. A procedure such as 96410, for example, likely would not be billed or would be submitted with a code Medicare no longer recognizes for hospital outpatient departments.

Weve found that some hospitals have lost as much as $30,000 in a month because they havent adjusted their charge masters, says Cindy Parman, CPC, CPC-H, principal and co-founder of Coding Strategies Inc., a coding consulting firm in Dallas, Ga.

Parman recommends that hospitals no longer rely on physicians to provide the proper code so the facility can bill for the procedure. Now, physicians have to capture different information than the hospital, she says. They have to provide CPT codes, while hospitals have to provide an APC code. You cant rely on (office-based) physicians to provide the proper APC codes.