Drug Waste

astuart@pmsia.com

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Hiawatha, IA
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I have a small hospital that is somewhat limited on the amounts of chemo drugs that they keep on site. When billing for waste, they would like to bill for the waste based off of the vial size that they have available, even if a small vial size is available on the market (they just don't carry it).

Example, they infuse 200mg of Drug X using 2 150mg vials therefore they waste 100mg
I have told them that I don't ethically believe that you can do this if a smaller vial size is available such as in the above example, if 50mg vials are available they could have used 1 150mg vial and 1 50mg vial and not had any waste.

What I am looking for, is #1: Am I correct in my thinking - that they should only waste up to the smallest available vial and #2: Is there any documentation that can support this?

Thanks in advance for your input.
 

kmd1965

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decatur, GA
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I haven't seen this language in the CMS information regarding the Jan 1 2017 requirement that all contractors have to implement processing the JW modifier.

But previous communications from CMS have given the guidance you're looking for.
The article below has the language that directs the provider to purchase and use the smallest dose available for purchase that could provide the appropriate dose for the patient. (bottom of page 3)

You might also give the guidance that since you have to report the NDC also, CMS knows the vial size and billing the way you described opens them up to scrutiny.


https://www.cms.gov/Outreach-and-Ed...k-MLN/MLNMattersArticles/downloads/SE1316.pdf

Good luck!
 
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Here's how it goes, going off your example:
Orders are for 200 mg of Drug X. The manufacturer sells Drug X in vials of 150 mg, 100 mg, and 50 mg. The facility only has 150 mg vials, so you'd end up discarding 100 mg as you mentioned. The facility can do this if they want to, BUT if they do, then they can't expect Medicare to pay for the drug waste, the facility would have to eat the lost profit.

The smart thing for a smaller facility to do is, if they don't want to stock a large supply, then forego the high dose vials and stock a large quantity of the lower(est) dose(s). In the example, let's say the orders are for 175 mg. If the facility only had 50 mg vials, only 25 mg would be discarded. Because 25 mg is less than the lowest dose possible for sale, the waste could be billed to Medicare and likely receive payment. In a coding scenario, you'd bill the used amounts and then a separate line item with a JW mod for the wasted amount.
 

astuart@pmsia.com

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Hiawatha, IA
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That is exactly what I was looking for...an affirmation that I was on the correct line of thinking and the MLN resource should be enough to convince the clinic.
Thanks so much!
 
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