All of the guidance I've seen regarding this is directed at the coding of the surgical treatment by the physician of the complication itself, not at the coding of any supplies or implants that might have been used in the process.
Assuming this occurs in a facility, any implants would always be a facility cost, not a physician charge, so my opinion is that it would be appropriate for the facility to charge for the implants. Facilities always report all of their costs involved in patient care and do not select out certain costs to not report based on any criteria such as this. (And even if you did not charge the implant on the claim itself, it will still appear on the facility's cost reports that are submitted to Medicare that are used in rate calculation.) In most cases, this extra charge for an implant would not affect the insurance payment or patient responsibility in any way since facilities are generally reimbursed at case rates which are inclusive to all services and supplies in the encounter. Unless you're dealing with a situation where a particular implant was very high cost and for which there was a carve-out or outlier payment in the particular payer contract that would apply, I think there wouldn't be any financial impact one way or the other. As a rule, the preventable occurrences in a facility are reported by diagnosis code and the 'Present On Admission' indicator, which will alert the payer to what has happened so that payment can be adjusted accordingly and there is no rule, that I'm aware of, governing what charges should or should not appear on the facility's claims due to complications.
