Oncology & Hematology Coding Alert

Question: Is it OK to bill Medicare for injections performed based on lab results (a sort of standing order)?

Michigan Subscriber

Answer: No. Medicare requires a signed physician order for any drug administered.

Consider the WPS document posted at www.accc-cancer.org/ossn_network/pdf/WPS-Chemo-Services-Error-Rates.pdf. It describes a case in which a practice billed a Neulasta injection, but the practice failed to submit valid orders for the date of service. When a Comprehensive Error Rate Testing (CERT) reviewer requested supporting documentation, the practice offered a Neulasta order from two months before the DOS and a note that "Based on the patient's lab values the patient received an injection of Neulasta. The patient did not see the physician that day, but the physician signed off on the flow sheet that documents the Neulasta injection."

WPS indicates that for a review, this documentation error can be avoided by:

• Following Medicare's signature requirements for ordered/provided services
• Documenting medical necessity and intent for chemotherapy-related services
• Including a signed physician order for administered drugs, including dose, frequency, and duration
• Submitting a copy of a protocol, if used.

Coding tip: The appropriate HCPCS code for Neulasta is J2505 (Injection, pegfilgrastim, 6 mg). For an injection, report 96372 (Therapeutic, prophylactic, or diagnostic injection [specify substance or drug]; subcutaneous or intramuscular).