Documentation for JW/JZ modifiers


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CMS guidance for JW/JZ modifiers states: Providers and suppliers must document the amount of discarded drugs in Medicare beneficiaries' medical records.
As a coder/auditor, I believe the amount administered and discarded should be documented in the provider's procedure note in order to charge the appropriate units. The provider's note should stand alone is a saying that I have utilized in my career as a coder/auditor. CMS guidance doesn't specify that it needs to be documented in the actual procedure note, it simply states it just needs to be documented in the medical record.

Question #1 - As a coder/auditor, would you code/charge medication waste if it was only documented in the MAR and not in the provider's note?
Question #2 - If the discarded amount is documented in the provider's note, would you code/charge if the waste was documented as:
  • The proximal interphalangeal joint cord of the right long finger was injected with 0.58mg of Xiaflex. The rest of the vial was discarded.
  • The proximal interphalangeal joint of the right ring finger was injected with 0.58mg of Xiaflex. The appropriate amount was discarded
Question #1 - When applying JZ modifier, do you require the provider to document a statement such as, "The entire vial was used to treat the patient" or "No medication waste"?
Question #2 - Do you apply the JZ based on the NDC, which tells you the vial size/strength, and the amount administered per documentation?

Please share any guidance you may have found in addition to CMS guidance. Thank you!!
No official references here, but I'll weigh in since no one else has. The "note should stand alone" to me does not mean only the document called note. For example, sometimes my clinicians draw a diagram for the patient that is scanned in and contains some additional information. The "note" doesn't have the diagram, but does reference it - it is a separate document. But both documents together make up the record for the day. Or maybe at 8pm the physician speaks with the patient's cardiologist that he/she tried to reach earlier in the day. If they create a new document instead of adding/amending the existing document, I don't know why you couldn't count the information. The same would apply here to me. As long as it's in the chart as part of the records signed by the physician for the day, I would not have a problem with it.
My practice does not currently supply/bill drugs, so I am not 100% up to date with the JW/JZ requirements. I will say I absolutely prefer rather than "rest of the vial" or "appropriate amount" to state the amount. There are meds that come in various sized vials. This is too vague for me, even if the NDC is noted. "0.42mg discarded" is not any harder than "The appropriate amount was discarded." but leaves zero room for a misinterpretation or ding on an audit.

EDIT: Didn't realize this was a duplicate post and there are more answers/resources in your original post:
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