re: ivig administration codes, rac...
TRANSCRIPT
www.infusioncenter.net
May 26, 2011
Re: IVIG Administration Codes, RAC Audits
Arnold Balanoff, MD
Chief Medical Officer
Office of the Regional Administrator
601 E. 12th Street, Suite 235
Kansas City, MO 64106
In order to provide clarity to providers, reduce cost to CMS and increase patient access to IVIG, CMS
should publish a notice that chemotherapeutic administration codes for IVIG should be allowed, and the
current RAC audits regarding the use of chemotherapy admin codes with IVIG should be dismissed.
Beginning in November 2010, the NICA received notice from our partners that certain Medicare
Contractors, were denying and/or down‐coding high‐level chemotherapy administration codes on IVIG
(Intravenous Immune globulin) claims to lower‐level therapeutic administration codes. In May 2011,
certain Recovery Audit Contractors (RACs) such as Connolly Healthcare began conducting audits in
attempts to recover suspected “overpayments” on certain providers who billed the chemotherapeutic
code (complex‐chemo admin codes) rather than the therapeutic code when administering IVIG.
Chemotherapeutic Codes (IVIG administration codes being denied or down‐coded):
96413 ‐ Chemotherapy and Complex drugs; Biologicals: Intravenous Infusion up to one hour 96415 ‐ Chemotherapy and Complex drugs; Biologicals: Intravenous Infusion each additional hour Therapeutic Administration Codes: 96365 ‐ Intravenous infusion, for therapy, prophylaxis, or diagnosis; initial, up to 1 hour 96366 ‐ Intravenous infusion, for therapy, prophylaxis, or diagnosis; each additional hour History:
The allowed use of the chemotherapy administration codes for non‐chemotherapeutic medications is
common place among all payers, including CMS and its Medicare Contractors. For intravenous therapies
that are deemed complex, including some specialty biological and monoclonal antibody drugs,
contractors have allowed providers to bill the higher level chemotherapy administration codes. Many
MACs have published specific instructions regarding medications that may be billed with complex‐
chemo admin codes. To view a specific example, please see the Trailblazer notice titled, “Chemotherapy
Administration Coding” issued on July 21, 2010. The notice specifically outlines many non‐
chemotherapeutic drugs that may be billed with complex‐chemo admin codes. The notice specifically
states that the list of drugs that may be billed with complex‐chemo admin codes is not intended to be
complete, and it allows complex‐chemo admin codes to be billed when medications require “physician
work or clinical staff monitoring well beyond that of therapeutic drug agents (CPT codes 96360–96379).”
www.infusioncenter.net
A copy of the notice can be found at the following link:
http://www.trailblazerhealth.com/Tools/Notices.aspx?DomainID=1&ID=13802
Immediate Dismissal of RAC Audits:
The current RAC audits should be dismissed based on the fact that no policy prohibiting billing the
complex‐chemo admin code for IVIG or any other complex intravenous medication is readily
ascertainable.
After speaking with our partners and researching this issue thoroughly, we have found no evidence of a
CMS, local Medicare contractor (MAC), or any other regulating body policy stating that IVIG could not or
should not be billed with complex‐chemo admin codes (96413‐96415).
Our research did find an Office of the Inspector General (OIG) report dated June 2009, titled “Chemotherapy Administration: Payment and Policy” that states in their findings,
“Carriers have implemented inconsistent chemotherapy administration coding polices and review procedures"
The same OIG report recommends that CMS:
“Establish a process to determine which specific drugs qualify for the chemotherapy administration rate.”
Because (i) no policy prohibiting billing complex‐chemo admin codes with IVIG is available and (ii) the OIG Report’s recommendation, the RAC audits should be dismissed. IVIG warrants coverage using chemotherapeutic administration code: IVIG at least warrants the same administration coverage as other monoclonal class drugs such as
Remicade, Orencia, and Rituxan due to the increased patient monitoring and administration burdens
associated with administering IVIG (see Trailblazer LCD below). Clinically, it is well understood that that
IVIG is at least as complex as the chemotherapeutic and non‐chemotherapeutic medications currently
covered under the complex‐chemo admin codes. (Please see attached chart titled – “Medication
Comparison”). Therefore, the administration of IVIG should be paid at a higher level than the
administration of Ceftriaxone (Rocephin), Cipro, and other non‐complex therapies.
Trailblazer Health’s LCD (local coverage determination) for IVIG acknowledges that IVIG is clinically
difficult to administer:
“Sensitivity to these (IVIG) reactions is usually related to the infusion rate. Caution should be
exercised in the administration of intravenous immune globulin; reactions may cause a rapid fall
in blood pressure and clinical anaphylaxis.”
www.infusioncenter.net
Solution: Increase Patient Access and reduce CMS costs:
The issue of clarifying appropriate administration codes for specialty medications is a core objective of
the NICA. We believe it is in the favor of all parties to establish a set criterion for providers that define all
specialty injectable/infusible medications and their appropriate administration codes. Providers who
remain uncertain about CMS or Medicare contractor policies for administration codes are more likely to
not offer these medications in their practice out of concern for possible future auditing and medical
review. This uncertainty means more patients will have to receive these specialty medications at a non‐
preferred, high‐cost facility such as a hospital where costs for the patient and payer can easily double
and increase by as much as 100%. It is proven that infusion therapy administered in a provider’s office is
significantly less expensive than the hospital.
Conclusion and Recommendations:
The NICA is asking CMS Medical Directors and appropriate staff to consider the benefits of the
discussion on this topic. Clarity on this issue will insure that chronically ill patients can continue to
receive their treatments in a lower cost, non‐hospital setting. Accordingly, the NICA is asking CMS to:
Publish a notice clarifying the allowed use of the higher‐level complex‐chemo codes when
administering biologic, specialty drugs like IVIG, and
Remove the RAC audit approved issue “Chemotherapy Administration Codes” and rescind the
corresponding RAC audits on the issue
If you have comments on this letter, you may email them to [email protected]
Thank you,
Bryan Johnson, President National Infusion Center Association
Enclosures:
1. Administration Code Comparison Chart
2. OIG Report, Medicare Part B Chemotherapy Administration Payment and Policy, June 2009
3. Trailblazer Chemotherapy Administration Code Policy dated July 21, 2010
*Some specialized therapeutic medications will require these conditions **IVIG preparation varies from Lyophilized & Liquid products/brands
Administration Code Comparison Chart Current Covered (96413, 96415) Medications vs. IVIG
From Trailblazer Health Enterprises LCD L26774: “Sensitivity to these reactions is usually related to the infusion rate. Caution should be exercised in the administration of intravenous immune globulin; reactions may cause a rapid fall in blood pressure and clinical anaphylaxis.”
MEDICATION
ADMINISTR
ATION REQ
UIREM
ENTS
Direct Physician/N
urse Supervision
Specialized
Preparation
Infusion Pump Recommen
ded
Pre‐Treatment Screening
Dosage Adjustmen
ts at Time of Treatm
ent
(weight‐based dosing)
Infusion Rate Change Required
During
Treatm
ent
PATIEN
T MONITORING
Freq
uent Vitals During Infusion
Freq
uent Assessm
ents During Treatm
ent
Post Infusion Instruction Recommen
ded
ADVER
SE EVEN
TS PROFILE
Higher Incidence of Infusion related
reactions
Higher Risk of Infusion Anaphylaxis
Increases/Decreases in
Blood Pressure
Avg. Treatment Inventory Cost
(Per Day)
Remicade X X X X X X X X X X X X $2,800-4,000 Actemra X X X X X X X X X $1,000-1,500 Rituximab X X X X X X X X X X X $3,000-7,500 Tysabri X X X X X X X X X X X $2,500 Xolair X X X X X X X X $600-2,400 Orencia X X X X X X X $600-1,200 Avg. Therapeutic Drug * * * * $5-150 IVIG (all brands) X X* X X X X X X X X X X $2,500-7,500
CONTACT US SELF-SERVICE TOOLS FAQS LISTSERVS NOTICES CALENDAR OF EVENTS HOW DO I?
Welcome. REGISTERLOGIN Search
This content pertains to...
Quick LinksFEE SCHEDULES
FORMS
LOCAL COVERAGE DETERMINATIONS
EVALUATION AND MANAGEMENT
Printable View
RSS Feed
Site Tutorial
Download Adobe Reader
TrailBlazer Sites
Medicare Home Page
Corporate
We Are Listening!
Send us your Web site feedback.
Visit the Program Safeguard Contractor for the J4 MAC areas.
Notices
Medicare Home Page Notices
CMS and TrailBlazer Are Official Sources for Medicare Information
All TrailBlazer Part A and Part B notices will be posted to this site. Users are able to view the latest information from TrailBlazer and CMS, such as CR or JSM instructions, or easily retrieve the most up-to-date information without searching the entire site. The CMS mandated notices will include a link to the CMS Web site where providers may view the transmittals in their entirety. For your convenience, notices are listed in date order with the most current being shown first. This page is updated daily.
Search other Notices
Chemotherapy Administration Coding(7/21/2010)
TrailBlazer’s Medical Review staff recently performed a number of audits on several drugs and associated drug administration codes. Findings of the audit indicate the need for review of the proper use of chemotherapy administration CPT codes 96401–96549. The full instructions for the use of these codes are located in two separate documents. The chemotherapy administration CPT codes (96401–96549):
Are used to report the administration of certain non-radionuclide drugs when the infusion requires physician work or clinical staff monitoring well beyond that of therapeutic drug agents (CPT codes 96360–96379).
•
Apply to parenteral administration of non-radionuclide antineoplastic drugs, antineoplastic agents provided for the treatment of non-cancer diagnoses (e.g., cyclophosphamide for autoimmune conditions), substances such as monoclonal antibody agents and other biologic response modifiers.
•
Drugs commonly falling in the category of monoclonal antibodies include infliximab, rituximab, alemtuzumb, gemtuzumab and trastuzumab. Drugs commonly falling in the category of hormonal antineoplastics include leuprolide acetate and goserelin acetate. The drugs listed above are not intended to be a complete list of drugs that may be administered using the chemotherapy administration codes. The chemotherapy administration CPT codes (96401–96549) may not be used to report administration of:
Substances used as diagnostic agents such as radio-opaque dyes. •Therapeutic radionuclides (use CPT codes 79101, 79403 or 79999). •Anti-anemia drugs. •Anti-emetic drugs. •Hydration fluids. •Drugs that appear on the “usually self-administered” drug exclusion list. •
If performed to facilitate the chemotherapy infusion or injection, the following services and items are included in the payment for CPT codes 96401–96549 and are not separately billable/payable:
Use of local anesthesia. •Establishing IV access. •Access to indwelling IV, subcutaneous catheter or port. •Flush at conclusion of infusion. •Standard tubing, syringes and supplies. •Preparation of chemotherapy agent(s). •
If a significant, separately identifiable Evaluation and Management (E/M) service is performed, the appropriate E/M code should be reported utilizing modifier 25 in addition to the chemotherapy code. For an E/M service provided on the same day, a different diagnosis is not required. Additional detailed information is available in the preamble of the CPT codebook and in the Internet-Only Manual (IOM) Pub. 100-04, Medicare Claims Processing Manual, Chapter 12, Section 30.5.D. (Reference: From the Desk of the Medical Director)
Programs: Part A,Part BTopics: Policies, Specialty ServicesSubtopics: Chemotherapy, Contractor Medical Directors, Drugs and Biologicals
AMA CPT / ADA CDT Copyright Statement
CPT codes, descriptions and other data only are copyright 2010 American Medical Association (or such other date of publication of CPT). All Rights Reserved. Applicable FARS/DFARS Clauses Apply. Current Dental Terminology, (CDT) (including procedure codes, nomenclature, descriptors and other data contained therein) is copyright by the American Dental Association. © 2010 American Dental Association. All rights reserved. Applicable FARS/DFARS apply.
APPEALS
AUDIT & REIMBURSEMENT
BENEFICIARY
CERT
CLAIMS
CUSTOMER SERVICE
EDUCATION
EDI
FACILITY TYPES
MSP
PAYMENT
POLICIES
PROVIDER ENROLLMENT
PUBLICATIONS
QUALITY INITIATIVES
SPECIALTY SERVICES
Page 1 of 2Notices | Tools | TrailBlazerHealth.com - Chemotherapy Administration Coding
4/11/2011http://www.trailblazerhealth.com/Tools/Notices.aspx?DomainID=1&ID=13802