Pharmacy Question for the Week of May 14, 2018

We are looking for clarity about billing for immunosuppressive drugs. If a supplier mailed an immunosuppressive drug shortly before the end of a beneficiary’s inpatient stay and used the mailing date as the date of service, would the claim be rejected if this happened because the claim’s date of service preceded the beneficiary’s date of discharge?

Read More

Sexually Transmitted Disease Awareness

CMS encourages providers to talk, test, and treat STDs. When it comes to sexually transmitted disease (STD) awareness, the Centers for Medicare & Medicaid Services

Read More

General Question for the Week of May 7, 2018

I read the answer to your March 19 question, and I don’t believe the response from MedLearn completely answers the question posed by the writer. Specifically:

• The question did not mention anything about a patient being seen in different hospital departments.
• The response refers to the NCCI Policy Manual for Medicare Services, chapter XI, section B, item 4, indicating that the following guideline can be found there: “When the PICC is inserted/placed by the same department (cost center) then the IV Infusion/injection is considered a component of the procedure and not separately billable.” However, I do not see any reference in the NCCI manual guidance about the same department (cost center). For this chapter, go to file:///C:/Users/Tillie/AppData/Local/Temp/Temp1_NCCI-Policy-Manual-2018.zip/CHAP11-CPTcodes90000-99999_final%20103117.pdf.
My interpretation of the NCCI manual guidance, item 4 is as follows: It states that placement of peripheral vascular access devices is integral to IV infusion and injections and not separately reportable (e.g., 36000—introduction of needle/catheter into vein), 36410—venipuncture). This guidance is also documented in the CPT manual under the Vascular Injection Procedures section, which is referring to intravenous injection procedures into veins and arteries or catheters (e.g., peripheral IV access.)

However, per the NCCI guidance, if it is central venous access (e.g., CPT 36568, 36569), which is not routinely necessary to perform infusions/injections, this service MAY be reported separately. Central venous access procedures are different than vascular injection procedures.

So, if a PICC meets the description of a peripherally inserted central venous catheter (per the CPT manual) “to qualify as a central venous access catheter or device, the tip of the catheter/device must terminate in the subclavian, brachiocephalic (innominate) or iliac veins, the superior or inferior vena cava , or the right atrium” then when CPT codes for central venous access catheter procedures are reported with a CPT code for the IV infusion/injection administered on the same day, per the CPT manual and NCCI manual guidance and instruction it is appropriate to report it with the -59 or XU modifier regardless of the same department or revenue center.

I would appreciate your review of the initial question and my comments and any additional explanation or information you could provide on this issue.

Read More

Featured Webcasts

Surviving Federal Audits for Inpatient Rehab Facility Services

Surviving Federal Audits for Inpatient Rehab Facility Services

Federal auditors are zeroing in on Inpatient Rehabilitation Facility (IRF) and hospital rehab unit services, with OIG and CERT audits leading to millions in penalties—often due to documentation and administrative errors, not quality of care. Join compliance expert Michael Calahan, PA, MBA, to learn the five clinical “pillars” of IRF-PPS admissions, key documentation requirements, and real-life case lessons to help protect your revenue.

November 13, 2025
E/M Services Under Intensive Federal Scrutiny: Navigating Split/Shared, Incident-to & Critical Care Compliance in 2025-2026

E/M Services Under Intensive Federal Scrutiny: Navigating Split/Shared, Incident-to & Critical Care Compliance in 2025-2026

During this essential RACmonitor webcast Michael Calahan, PA, MBA Certified Compliance Officer, will clarify the rules, dispel common misconceptions, and equip you with practical strategies to code, document, and bill high-risk split/shared, incident-to & critical care E/M services with confidence. Don’t let audit risks or revenue losses catch your organization off guard — learn exactly what federal auditors are looking for and how to ensure your documentation and reporting stand up to scrutiny.

August 26, 2025
The Two-Midnight Rule: New Challenges, Proven Strategies

The Two-Midnight Rule: New Challenges, Proven Strategies

RACmonitor is proud to welcome back Dr. Ronald Hirsch, one of his most requested webcasts. In this highly anticipated session, Dr. Hirsch will break down the complex Two Midnight Rule Medicare regulations, translating them into clear, actionable guidance. He’ll walk you through the basics of the rule, offer expert interpretation, and apply the rule to real-world clinical scenarios—so you leave with greater clarity, confidence, and the tools to ensure compliance.

June 19, 2025

Trending News

Featured Webcasts

Sepsis: Bridging the Clinical Documentation and Coding Gap to Reduce Denials

Sepsis: Bridging the Clinical Documentation and Coding Gap to Reduce Denials

Sepsis remains one of the most frequently denied and contested diagnoses, creating costly revenue loss and compliance risks. In this webcast, Angela Comfort, DBA, MBA, RHIA, CDIP, CCS, CCS-P, provides practical, real-world strategies to align documentation with coding guidelines, reconcile Sepsis-2 and Sepsis-3 definitions, and apply compliant queries. You’ll learn how to identify and address documentation gaps, strengthen provider engagement, and defend diagnoses against payer scrutiny—equipping you to protect reimbursement, improve SOI/ROM capture, and reduce audit vulnerability in this high-risk area.

September 24, 2025
2026 IPPS Masterclass 3: Master MS-DRG Shifts and NTAPs

2026 IPPS Masterclass Day 3: MS-DRG Shifts and NTAPs

This third session in our 2026 IPPS Masterclass will feature a review of FY26 changes to the MS-DRG methodology and new technology add-on payments (NTAPs), presented by nationally recognized ICD-10 coding expert Christine Geiger, MA, RHIA, CCS, CRC, with bonus insights and analysis from Dr. James Kennedy.

August 14, 2025
2026 IPPS Masterclass Day 2: Master ICD-10-PCS Changes

2026 IPPS Masterclass Day 2: Master ICD-10-PCS Changes

This second session in our 2026 IPPS Masterclass will feature a review the FY26 changes to ICD-10-PCS codes. This information will be presented by nationally recognized ICD-10 coding expert Christine Geiger, MA, RHIA, CCS, CRC, with bonus insights and analysis from Dr. James Kennedy.

August 13, 2025

Trending News

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24