The article you've attached here is the preliminary recommendation, in response to an application, of the committee regarding whether or not to adopt a new HCPCS code. This isn't regulatory guidance on whether or to code or bill for the item. (Incidentally, this was published in June, 2020, and there is a more recent publication from December of that year with a revised recommendation to refer the item to the AMA for the creation of a new CPT code for use in reporting the injection service done in advance of the procedure, as you describe. You can find this document here:
https://www.cms.gov/files/document/...gical-items-and-services-december-21-2020.pdf)
I'd also add that the committee has not stated in either case that it considers the item 'bundled' (which is a coding concept that would apply only to reporting of items or services provided in the same encounter and/or on the same date of service), but rather that the payment for the item is included in the payment for the procedure in which it is used - for hospital purposes, this would be considered a 'packaged' item, not bundled, under OPPS reimbursement methodology. Per CMS guidelines hospitals "
should report charges for all drugs, biologicals, and radiopharmaceuticals, regardless of whether the items are paid separately or packaged" (see Medicare Claims Processing Manual- Chapter 17, section 90.2), so it should definitely be charged and reported on the claim as a hospital cost, even if separate payment is not expected.
I'm not able to find any more current information than these documents so I don't have a definitive source to back this up, but in my opinion it's appropriate and correct to charge for this - my recommendation would be to use an unlisted code for both the product (if required on the revenue code) and the injection procedure until such time as a more specific code is create and/or additional guidance is given. Hopefully that makes sense and will help some.
