Wiki Pre Op Injection Administration

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I am an auditor and have a hospital who wants to charge administration for Pre-Op IVP Versed (96374). I have explained that this would be considered part of the facility's Global Surgical Package as anesthesia writes for the medication when they begin to prep their patient for the operating room. Can someone please give me guidance on this? It is written in the NCCI Process Manual that Anesthesia starts when the practitioner begins to prepare the patient for anesthesia services in the operating room or an equivalent area (pre-op). Jan 1 they started adding the charge for Pre-Op antibiotic administration (96365) also, but we explained to them that Pre Op antibiotics are part of the Global Surgical Package, and now this discussion has come about. I am telling them they may charge for Pre-Op Zofran as long as it is not integral to the surgery, but that Versed is part of the Anesthesia Process - regardless if they're using General, Mac, or Moderate Sedation.

Thanks in advance for any response!
 
Are you auditing facility or physician claims here? Global Surgical Package is a physician coding concept and not applicable to facility claims, which are charged and coded largely based on cost reporting and reimbursement policy rules. Facilities may report their charges for the costs of these administrations, but as long as they are not inappropriately adding a modifier to unbundle these and create a separate APC payment for the administration, then it would not necessarily contract the NCCI rules and it should not impact reimbursement. If they are adding a modifier to bypass the edits, the I would agree this is not appropriate if the administration is related to the surgical procedure. In other words, facilities may charge for these services as a part of the costs that they incur, but they should not code these services as separately identifiable procedures unless the NCCI guidelines are met, at least for payers that follow these policies.
 
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"Facilities may report their charges for the costs of these administrations, but as long as they are not inappropriately adding a modifier to unbundle these and create a separate APC payment for the administration, then it would not necessarily contract the NCCI rules and it should not impact reimbursement. If they are adding a modifier to bypass the edits, the I would agree this is not appropriate if the administration is related to the surgical procedure. In other words, facilities may charge for these services as a part of the costs that they incur, but they should not code these services as separately identifiable procedures unless the NCCI guidelines are met, at least for payers that follow these policies."

It is facility coding. I did explain they could roll all the administration charges into Rev Code 0260 without the CPT code on it (charging without coding), but they want to put an XU modifier on the injection administration for Versed and Zofran administration as rolling it into the Rev Code will get them nothing from Medicare. They tell me since it is not an integral part of the surgery, it should be charged as above and beyond. This to me is unbundling as pain management is considered part of the surgery - or at least part of the anesthesia prep for the surgery. On the other hand, for some patients they give a Pre Op Zofran Injection - for instance the patient states they get nauseous from all types of anesthesia. In this case, it is not integral to the surgery, but is patient specific and therefore can be coded and charged as a separate procedure - right?

I am specifying the drugs as I believe there is a difference between the administration of an anesthetic agent to prep for surgery compared to administration of a patient specific med. Or are they both considered part of the surgery and neither should be coded?

I am good at taking constructive criticism and only want to get this right. OK if you tell me I'm wrong!

Thanks for your response!
 
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