Transfusion Confusion: How to Avoid Being a RAC Target Presented by: Robin Miller Zweifel, BS, MT(ASCP) Vice President of Clinical Consulting Services Panacea Healthcare Solutions May 28, 2013 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 1 Disclaimer • • • • • • Panacea has prepared this seminar using official Centers for Medicare and Medicaid Services (CMS) documents and other pertinent regulatory and industry resources. It is designed to provide accurate and authoritative information on the subject matter. Every reasonable effort has been made to ensure its accuracy. Nevertheless, the ultimate responsibility for correct use of the coding system and the publication lies with the user. Panacea, its employees, agents and staff make no representation, warranty or guarantee that this information is error-free or that the use of this material will prevent differences of opinion or disputes with payers. The company will bear no responsibility or liability for the results or consequences of the use of this material. The publication is provided “as is” without warranty of any kind, either expressed or implied, including, but not limited to, implied warranties or merchantability and fitness for a particular purpose. The information presented is based on the experience and interpretation of the publisher. Though all of the information has been carefully researched and checked for accuracy and completeness, the publisher does not accept any responsibility or liability with regard to errors, omissions, misuse or misinterpretation. Current Procedural Terminology (CPT ®) is copyright 2011 American Medical Association. All Rights Reserved. No fee schedules, basic units, relative values, or related listings are included in CPT. The AMA assumes no liability for the data contained herein. Applicable FARS/DFARS restrictions apply to government use. CPT® is a trademark of the American Medical Association. Copyright © 2013 by Panacea. All rights reserved. No part of this presentation may be reproduced in any form whatsoever without written permission from the publisher Published by Panacea, 287 East Sixth Street, Suite 400, St. Paul, MN 55101 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 2 Cost associated with Purchase • • • • • • Costs associated with acquisition, storage and processing of blood and blood products continues to escalate each year. In 2011 it was estimated that more than 14 million units of red blood cells were transfused annually in the United States. Information from this study was taken from a total of 213 surveys completed by hospital-based blood bank and transfusion service directors. The study cited significant statistical variation in acquisition cost by US census region, division and type of facility. The mean (SD) acquisition cost for one unit of red blood cells purchased from a supplier ranged from $172 to $248 with a national mean of $210.74 The mean charge to the patient by the hospital was reported to be between $208 and $478 with a national mean of $343.63. Based on information submitted by facilities participating in the survey the variance in associated costs to perform mandated screening was significant median cost to perform mandated screening procedures (n = 56) was $50.00 ± 120 per unit median storage and retrieval cost (n = 46) was $68.00 ± 81 per unit. http://www.ncbi.nlm.nih.gov/pubmed/21174480 Costs to hospitals of acquiring and processing blood in the US: a survey of hospital-based blood banks and transfusion services. Toner RW, Pizzi L, Leas B, Ballas SK, Quigley A, Goldfarb NI. ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 3 Cost associated with Transfusion • Considering all complex cost factors leading up to and after a red blood cell transfusion. Transfusion cost is $522 to $1,183 per unit. 37% higher than estimated by prior studies Annual transfusion costs total $1.6 to $6 Million per hospital surveyed. Failure to report transfusion, blood product processing charges and pretransfusion tests impacts reimbursement today and tomorrow. Facilities should NOT assume that transfusion services are consistently charged, that charges drop to claims or that claims are paid. New Published Study Finds the Cost of Blood Transfusions is Significantly Under-Estimated, Establishes True Cost at $522 to $1,183 Per Unit - Annual Costs Total $1.6 to $6 Million Per Hospital Surveyed—Warranting Improved Conservation & Cost Containment Strategies http://www.prnewswire.com/news-releases/new-published-study-finds-the-cost-of-blood-transfusions-is-significantly-under-estimated-establishes-true-cost-at-522-to1183-per-unit-89909747.html ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 4 Cost of Incomplete Processes • Auditors consistently find significant issues on claims for transfusions and transfusion related services The issues associated with blood/blood products can stem from: Charge master structure Late charge entry for blood product Account posting errors for patients with multiple, open accounts Misinterpretation of CMS billing directives Inappropriate bundling of charges and / or service unit issues Transfusions are an identified RAC issue Blood Transfusions, with CPT codes 36430, 36440, 36450, and 36455 should be billed as one (1) per session, regardless of the number of units transfused on any given date of service ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 5 Today’s Objectives • Provide simple guidance and assistance that will prepare you to: Evaluate charge capture for transfusion and transfusion related services Pre-transfusion testing Blood product processing, and Blood administration Identify potential issues which may require investigation / remediation HCPCS codes for products Revenue code assignment Units issues Missed / Lost charges Bundled charges ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 6 Processes to Review • Coding and charge submission for: Laboratory testing of the patient (CPT 86850-86999) In house testing (e.g., ABO / Rh typing, crossmatch) Referred testing (e.g., antibody ID’s) Autologous donor product Directed donor product Blood bank physician services (CPTs 86077-86079) Blood product storage / processing Routine processing (HCPCS P codes) Additional processing o Freezing, thawing, splitting of units (CPT 869XX codes) Blood administration / transfusion (CPT 36430-36460) Administrative Overhead Cost Accounting Delivery fees, stat or after hour charges ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 7 Other Potential Processes • Facilities who operate donor centers must assess charge capture and claim submission for: Product Acquisition Costs (HCPCS P codes) in addition to blood processing costs Assignment of modifier BL Assignment of revenue code 038X ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 8 Transfusion Services • Most healthcare facilities will provide one or more of the following transfusion services: Product storage Serologic testing for Compatibility Product selection for Transfusion Issuance of selected blood and components as ordered Exceptions: • The facility providing transfusion services does not usually collect blood or process whole blood into components. • Some facilities may provide limited services for separation of whole blood to red blood cells and recovered plasma. ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 9 Blood Collection Center • FDA/CBER is responsible for regulatory oversight of the U.S. blood supply. • • FDA promulgates and enforces standards for blood collection and for the manufacturing of blood products, including both transfusible components of whole blood, pharmaceuticals derived from blood cells or plasma, and related medical devices. Blood in the U.S. is collected by FDA-licensed collection centers. Each donated unit intended for transfusion must be labeled by the collection center as either paid donor or volunteer donor. According to FDA regulation “if a donor receives monetary payment for a blood donation, all products collected from that donor that are intended for transfusion and that are collected during the donation at which the donor received the monetary incentive must be labeled with the "paid donor" classification statement.” The FDA regulation also specifies benefits that would not require the "paid donor" classification statement and all products that are collected from that donor that are intended for transfusion may be labeled with the "volunteer donor" classification statement. ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 10 Q&A – American Red Cross Q. A. Does the American Red Cross pay blood donors? No. All Red Cross blood donors are volunteers. In fact, all blood collected for transfusion in the United States must be from volunteer donors. ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 11 Q&A – American Red Cross Q. A. Why am I charged for blood at the hospital when I have donated blood to the Red Cross previously? Since 1960, the Red Cross has been reimbursed by hospitals for the costs associated with providing blood to hospital patients. The Red Cross does not charge for the blood itself that you have so generously donated. The Red Cross only recovers the costs associated with the recruitment and screening of potential donors, the collection of blood by trained staff, the processing and testing of each unit of blood in state-of-the-art laboratories, and the labeling, storage, and distribution of blood components. Hospitals may have their own additional charges related to the administration of blood and may pass on these costs to their patients. ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 12 Helpful Resource Documents • • • The Centers for Medicare and Medicaid Services (CMS) responded to a request from the blood banking community for clarification of agency guidance regarding billing for blood products and related services. In late 2005, AABB, the American Red Cross (ARC), America’s Blood Centers (ABC) and the Advanced Medical Technology Association (AdvaMed) wrote to CMS commenting on CMS Transmittal 496 (March 4, 2005) and providing recommendations for improved guidance related to both outpatient and inpatient reimbursement for blood products and services. A summary of the blood community’s questions/recommendations along with CMS’ responses regarding coding requirements are accessible at the link below: http://www.aabb.org/programs/reimbursementinitiatives/Pages/cmsrespsumm.aspx ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 13 Helpful Resource Documents • Medicare Claims Processing Manual (100-04) Chapter 4 - Part B Hospital Section 231 - Billing and Payment for Blood, Blood Products, and Stem Cells and Related Services Under the Hospital Outpatient Prospective Payment System (OPPS) http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c04.pdf • CMS CR Transmittal #: R1495CP • Related MLN Matters Number: MM5867 Related Change Request (CR) #: 5867 Release Date: May 2, 2008 Effective Date: October 1, 2008 Implementation Date: October 6, 2008 CMS Transmittal 1702 CR 6416 Release Date: March 13, 2009 Effective Date: April 1, 2009 Implementation Date: April 6, 2009 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 14 Apply the Statistics • Helpful numbers to keep in mind when looking for disconnects. Nationally, the percentage of inpatients who receive blood falls between 5% and 7%. The average number of units transfused to the inpatient is 3. Use this ‘given’ to estimate anticipated inpatient blood use. Two units of blood are typically infused in an outpatient transfusion encounter (approximately 80% in most studies). Use this ‘given’ to estimate anticipated inpatient blood transfusions. Use this ‘given’ to estimate anticipated outpatient blood use. Infusion time is typically 98 minutes for the first unit and 92 minutes for the second unit. Use this ‘given’ to estimate if charges cover cost. ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 15 Practice Facts • The number of each ABO (CPT 86900), Rh (D) (CPT 86901) and antibody screen (CPT 86850) should exceed the number of actual transfusions • Every patient transfused must be typed and screened Every patient who potentially may need blood is also typed and screened The number of cross matches should exceed the number of actual transfusions by a ratio of 4 to 1 Patient’s blood is cross matched in anticipation of a need for blood during surgery The number of cross matches performed is two or more per patient tested. Many cross matches are performed but blood is not always transfused Blood banks may report more than one CPT depending on the method used for the cross match ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 16 Q: What’s Wrong? On review of a university based facility’s revenue and usage statistics, it was observed that: Annual transfusions for CY 2012 total 4365 35,183 blood products were charged 20 of 55 line items show utilization All transfusions are reported from the ED and Infusion Center and Oncology Center No transfusions are reported from surgery, PACU, Recovery, Observation, Inpatient Units or Dialysis 11 blood product charge codes show activity Total Cross matches (compatibility tests) number 48,621 CPT 86920 CPT 86922 CPT 86923 44,609 4,012 0 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 17 A: Charge Capture • Transfusions may be improperly bundled to procedures, inconsistently or not reported at this facility. • This facility may be failing to capture >$2 million reimbursement for the transfusion procedure based on the volume of products transfused vs transfusions reported. • • Blood transfusions are not being reported when performed in surgery. Transfusions are performed but not reported in other cost centers with <5000 transfusions reported and >35,000 blood products charged. Blood products are not reimbursed if a transfusion CPT is not reported on the claim with the blood products. The number of transfusion procedures billed is significantly less than anticipated indicating a potential issue with charge capture. Disconnects can be identified utilizing revenue and usage statistics. ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 18 Investigating Disconnects • Review transfusion related revenue and usage statistics with the blood bank supervisor / manager and / or director. • • Compare BB transfusion records to facility revenue and usage Review statistics to determine if HCPCS P codes assigned to active charge lines reflect the variation of products transfused, (e.g. if all products are described in the charge master and the correct coding distinction is made.) Compare blood bank test records to confirm that the numbers of pre-transfusion / blood matching tests performed are reflected in the revenue and usage statistics. Pull claims, detail bills and remits for five outpatient transfusion encounters and five inpatient encounters with blood transfusion to validate any perceived disconnects. Identify department or units where blood is given in the facility and schedule meetings with the department managers to discuss transfusion charge capture processes. ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 19 Resources / References • • • • • • Current AMA CPT codebook Current HCPCS Level II Code Book Facility charge master Facility Revenue and Usage Statistics Sample Claims and detail bills with remits CMS Billing Guidelines • Medicare Claims Processing Manual, Chapter 4, §231-Billing and Payment for Blood and Blood Products Under the Hospital Outpatient Prospective Payment System (OPPS) available at http://www.cms.gov/manuals/downloads/clm104c04.pdf OPPS APC Addendum B payment rates Check the website of your local CMS Part A MAC ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 20 Inpatient/Outpatient Distinction • • CMS discusses the importance of charging all services consistently between inpatients and outpatients throughout the 2009 IPPS Final Rule OPTIONAL • Hospitals are free to create a separate charge for inpatient blood administration provided to patients in routine (room & board) cost centers REQUIRED Hospitals are expected to create a separate charge for blood administration in an ancillary department, such as the emergency department, operating room or infusion center for both inpatients and outpatients http://edocket.access.gpo.gov/2008/E8-17914.htm See pages 48465-48466 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 21 Routine or Ancillary? • • • CMS discusses routine versus ancillary in the Provider Reimbursement Manual (PRM-I) under Sections 2202.6 and 2202.8 Blood transfusion and blood products are not specifically mentioned in the definition of ‘routine services’ in the PRM-1 under Section 2202.6 or in the definition of ‘ancillary services’ in Section 2202.8. If an item is not specifically enumerated in the above sections, rules in Section 2203 of the PRM-I apply. This section requires that the common or established practice of providers of the same class in the same state should be followed. If there is no common or established classification among providers of the same class in the same State, a provider’s customary charging practice is recognized so long as it is consistently followed for all patients… ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 22 Charge Capture Responsibility • Transfusion services are typically provided in: • The charge function for blood administration typically occurs in a clinical area. • Inpatient rooms including Newborn Nursery and PICU Observation unit Surgery or recovery Chemotherapy / Infusion Center Emergency Department Dialysis Transfusion charge codes (36430-36460 as applicable) should be in the charge master in each department where blood is transfused. The Laboratory is responsible for charging product acquisition, processing and transfusion related ‘blood matching’ tests. Serologic / Crossmatch procedures Product storage & processing ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 23 Referred Tests • Blood suppliers provide reference laboratory testing • Facilities pay for the referred tests but often fail to charge patients Facilities who do charge may assign incorrect CPT code or billing units Identify charge disconnects and potential for lost or risk charge 1. Obtain the most recent supplier invoice 2. Identify reference laboratory tests that are separately billable to a patient 3. Cross walk the charges to the applicable patient accounts using information on the invoice or in the blood bank send out test log 4. Audit patient claims to determine if the tests were charged 5. Validate the CPT codes and billing units assigned 6. Validate that reference lab services are described in the charge master and included in the department IS or on order / entry screens ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 24 Unused Blood • Hospitals may not bill Medicare for unused blood. • • Units that are ordered but not transfused This longstanding policy applies to both the inpatient and outpatient setting. Hospitals may Bill for medically necessary laboratory services related to a specific patient (such as cross matching), even if the blood in not transfused Bill for medically indicated processing charges associated with preparation of a product that is not transfused and is discarded / destroyed Take the overall cost of unused blood into account when setting charges for units that are transfused ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 25 Unused Blood HCPCS Code Short Descriptor SI APC Relative Weight Payment Rate Minimum Unadjusted Copayment 86927 Fresh frozen plasma; each unit thawing X 0345 0.2519 $17.96 $3.60 86930 Frozen blood, each unit; freezing X 0347 0.4810 $34.30 $6.86 86931 Frozen blood, each unit; thaw X 0347 0.4810 $34.30 $6.86 86932 Frozen blood, each unit; freezing and thawing X 0347 0.4810 $34.30 $6.86 86945 Irradiation of blood product, each unit X 0345 0.2519 $17.96 $3.60 86960 Volume reduction of blood or blood product (eg, red blood cells or platelets), each unit X 0345 0.2519 $17.96 $3.60 86965 Pooling of platelets or other blood products X 0346 0.3504 $24.99 $5.00 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 26 Blood Bank Physician Services • • Blood bank physician services have a technical component and are separately payable Determination by the blood bank physician will determine final diagnosis code assignment = written report required HCPCS Code Short Descriptor SI APC Payment Rate 86077 Physician blood bank service; difficult cross match and / or evaluation of irregular antibody(s), interpretation and written report X 0433 $17.07 86078 Physician blood bank service; investigation of transfusion reaction including suspicion of transmissible disease, interpretation and written report X 0343 $36.48 86079 Physician blood bank service; authorization for deviation from standard blood banking procedures (e.g., use of outdated blood, transfusion of Rh incompatible units), with written report X 0433 $17.07 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 27 CMS IPPS Payment • • Blood product and transfusion payment is included in MS-DRG payment amount. CMS adopted a new inpatient cost-to-charge ratio (CCR) for blood and blood products in 2008. Hospital Charge x CCR = Medicare Payment Rates • To capture reimbursement: Set appropriate charges for blood and blood products Assign the correct revenue code(s) Consistently report charges on claims Department education required! ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 28 Cost Accounting • With respect to the cost report: • Hospitals are required to follow the Medicare cost apportionment regulations at 42 CFR 413.53(a)(1). The cost of each ancillary department is to be apportioned separately rather than combined with another department. The cost report includes a standard cost center for ‘Blood Storing, Processing and Transfusion” (Line 47 of Worksheet A, under the ‘’Ancillary Service Cost Centers’’). Hospitals must use billing codes as directed by the NUBC, regardless of the cost center in which the cost is reported on the cost report. When reporting the appropriate revenue code for services, hospitals should choose the most precise revenue code, or subcode if appropriate. ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 29 Revenue Codes • Three key revenue codes series • The appropriate revenue code for blood carrying only a processing fee is 0390 • 038X (Blood) 039X (Blood and Blood Component Administration, Processing, and Storage) 030X (Lab) The Red Cross and Community Blood Banks in the US do not charge hospitals for blood itself The Red Cross and Community Blood Banks in the US charge only for processing and handling Revenue code series 038X is not applicable for billing in most hospitals ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 30 Purchased Blood 0380 • When a hospital purchases blood or blood products from a community blood bank, or runs its own blood bank and assesses a charge for the blood or blood product, they report blood and blood products in Revenue Code Series 038X “Blood” along with the appropriate Healthcare Common Procedure Coding System (HCPCS) code Amount billed must reflect the hospital’s cost related to the purchase or collection of the blood or blood product The facility must also report Revenue Code 0390 with the appropriate HCPCS to reflect the cost of storage and processing Claims must include a line item for both 038X and 0390 in order to be processed The modifier “BL” must be appended to each line item as appropriate ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 31 Purchased Blood 0380 • • When reporting costs under the revenue code 038X series Payment for the following codes are applied to the blood deductible as instructed in the Medicare General Information, Eligibility and Entitlement Manual, Chapter 3, Sections 20.5 through 20.5.4: • • Medicare charges a blood deductible for the first three pints of blood given to a patient. Blood deductibles are charged for the cost of the blood product acquisition. A patient may elect to replace blood or for another to donate in the patients name • P9010, P9016, P9021, P9022, P9038, P9039, P9040, P9051, P9054, P9056, P9057, P9058 If all blood given to the patient is replaced, there is no charge for the blood Deductible amounts and replacements are reported through use of value codes on the claim Noridian Medicare Part A article: https://www.noridianmedicare.com/cgi-bin/coranto/viewnews.cgi?id=EkpAEFulFlwLpVYZwG&tmpl=part_a_viewnews&style=part_ab_viewnews ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 32 Blood Product Processing 0390 • When a hospital does not pay for the blood or blood product, it often incurs an administrative cost from a community blood bank for the bank’s processing, storage and related expenses Report these costs in Revenue Code 0390 “Blood Storage/Processing” • • 0392 and 0399 are alternative codes which may be assigned Report the HCPCS code assigned to the blood or blood product and the number of units transfused Do not charge for processing of a unit if the blood product is not transfused. with one exception…autologous blood processing The cross matching and pre-transfusion tests performed by the laboratory are billable even if blood is not transfused ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 33 Biologicals 0636 • • • Biologic products not paid on a cost or prospective payment basis are paid based on OPPS APC rate. Reimbursement rates for P9041, P9043, P9045, P9046, P9047, and P9048, are obtained from the Medicare drug pricing files. Albumin products are infused not transfused. Bill the administration of albumin products as drug administration Utilize CPT from 9636X series ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 34 Chargemaster Structure for Transfusion • • • • Transfusions must be billed per encounter, not per hour or per unit infused. Only one transfusion may be reported per day. Transfusion times and facility costs vary. Consider structuring the charge master as follows CPT Code CDM Description Rev Code Price 36430 Blood Administration, 0-2 hrs 0391 $ base 36430 Blood Administration 2-4 hrs 0391 $ base plus 36430 Blood Administration > 4 hrs 0391 $ base plus ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 35 OPPS Payment System • CMS APC payment rates for blood is charge based • Based on past Medicare claims Rate setting methodology resulted in decreased payment for the most commonly used blood products in CY 2010 Facility charge should reflect real costs Supplier Cost + Facility Cost of Entering Blood into Inventory= Product Cost Example: Hospital blood banks must perform confirmatory typing of units prior to entering them into the hospital inventory. This is an additional cost that should be reflected in the facility charge for the blood product when the product is transfused ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 36 Capturing OPPS Reimbursement APC Payment 2 units given w IS Xmatch 2 units given w AHG Xmatch CPT/ HCPCS Revenue Code ABO 86900 0300/302 $9.67 $9.67 $9.67 Rh 86901 0300/302 $9.67 $9.67 $9.67 Antibody Screen 86850 0300/302 $17.96 $17.96 $17.96 Crossmatch, IS 86920 0300/302 $17.96 $35.92 Crossmatch, Incubation 86921 0300/302 $17.96 Crossmatch AHG 86922 0300/302 $24.99 RBCs, LR per unit P9016 0390 $193.24 $386.48 $386.48 Blood Administration 36430 0391 $260.44 260.44 260.44 $720.14 $734.20 TOTAL ©2013 PANACEA Healthcare Solutions, Inc. 49.98 SLIDE 37 Blood Typing / Blood Matching American Red Cross Blood Typing Table ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 38 HCPCS Code Selection • When determining the appropriate HCPCS P-code for the blood product: Select the code that describes the base product as well as the attributes that reflect the way in which the product was processed If none of the available P-code descriptors exactly describes all of a product’s attributes, select the code that is the closest match Example: If leuko-reduced red blood cells are transfused, report: o HCPCS P-code whose descriptor includes both “red blood cells” and “leukocytes reduced,” o P9016 Red blood cells, leukocytes reduced, each unit ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 39 HCPCS Coding Options • • • There are thirty-five HCPCS codes that describe blood products – if you include the albumin codes OPPS reimbursement varies by product and attributes Don’t report ‘regular’ if ‘premium’ is provided For example P9019 P9031 P9032 P9033 P9034 P9035 P9036 P9037 Platelets, Platelets Platelets, Platelets Platelets, Platelets, Platelets, Platelets, each unit leukocytes reduced irradiated leukoreduced irradiated pheresis pheresis leukoreduced pheresis irradiated pheresis leukoreduced irradiated ©2013 PANACEA Healthcare Solutions, Inc. $91.61 $118.34 $134.23 $156.45 $431.99 $511.27 $675.77 $674.16 SLIDE 40 HCPCS Coding Options HCPCS Code Short Descriptor SI APC Relative Weight Minimum Unadjusted Payment Rate Copayment P9016 RBC leukocytes reduced R 0954 2.7097 $193.24 $38.65 P9017 Plasma 1 donor frz w/in 8 hr R 9508 1.1037 $78.71 $15.75 P9019 Platelets, each unit R 0957 1.2846 $91.61 $18.33 P9020 Platelet rich plasma unit R 0958 2.4626 $175.62 $35.13 P9021 Red blood cells unit R 0959 2.1285 $151.79 $30.36 P9022 Washed red blood cells unit R 0960 4.1562 $296.39 $59.28 P9023 Frozen plasma, pooled, sd R 0949 1.0129 $72.23 $14.45 P9031 Platelets leukocytes reduced R 1013 1.6595 $118.34 $23.67 P9032 Platelets, irradiated R 9500 1.8822 $134.23 $26.85 P9033 Platelets leukoreduced irrad R 0968 2.1939 $156.45 $31.29 P9034 Platelets, pheresis R 9507 6.0577 $431.99 $86.40 P9035 Platelet pheres leukoreduced R 9501 7.1694 $511.27 $102.26 P9036 Platelet pheresis irradiated R 9502 9.4761 $675.77 $135.16 P9037 Plate pheres leukoredu irrad R 1019 9.4536 $674.16 $134.84 P9038 RBC irradiated R 9505 2.8319 $201.95 $40.39 P9039 RBC deglycerolized R 9504 6.7273 $479.74 $95.95 P9040 RBC leukoreduced irradiated R 0969 3.8309 $273.19 $54.64 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 41 HCPCS Coding Options HCPCS Code Short Descriptor SI APC P9041 Albumin (human),5%, 50ml K 0961 P9043 Plasma protein fract,5%,50ml R 0956 P9044 Cryoprecipitate reduced plasma R 1009 P9045 Albumin (human), 5%, 250 ml K P9046 Albumin (human), 25%, 20 ml P9047 Relative Weight Minimum Unadjusted Payment Rate Copayment $22.63 $4.53 0.2848 $20.31 $4.07 0.9531 $67.97 $13.60 0963 $60.67 $12.14 K 0964 $30.24 $6.05 Albumin (human), 25%, 50ml K 0965 $69.20 $13.84 P9048 Plasmaprotein fract,5%,250ml R 0966 0.6613 $47.16 $9.44 P9050 Granulocytes, pheresis unit R 9506 22.6900 $1,618.09 $323.62 P9051 Blood, l/r, cmv-neg R 1010 2.5982 $185.29 $37.06 P9052 Platelets, hla-m, l/r, unit R 1011 10.8739 $775.45 $155.09 P9053 Plt, pher, l/r cmv-neg, irr R 1020 9.2615 $660.47 $132.10 P9054 Blood, l/r, froz/degly/wash R 1016 1.7169 $122.44 $24.49 P9055 Plt, aph/pher, l/r, cmv-neg R 1017 4.7192 $336.54 $67.31 P9056 Blood, l/r, irradiated R 1018 2.4667 $175.91 $35.19 P9057 RBC, frz/deg/wsh, l/r, irrad R 1021 5.1700 $368.69 $73.74 P9058 RBC, l/r, cmv-neg, irrad R 1022 4.0183 $286.56 $57.32 P9059 Plasma, frz between 8-24hour R 0955 1.0591 $75.53 $15.11 P9060 Fr frz plasma donor retested R 9503 0.7967 $56.82 $11.37 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 42 CPTs for Transfusion Medicine • See CPT series 86850-86999 • Assign revenue code 0300 or 0302 Follow coding directives seen in parentheticals throughout the section Report each code with the CPT defined unit of testing Each technique Each antiserum Per unit screened Each antigen Each screen Each unit Other Services – non-transfusion Therapeutic apheresis, see CPT 36511-36512 Therapeutic phlebotomy, see CPT 99195 ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 43 Autologous Blood • • When an autologous unit is unused and is destroyed, the hospital may bill for the special processing and handling cost with CPT code 86890 CMS states that the date of service must be the date on which it is known that the blood will not be transfused— typically, the date of discharge This determination must be indicated in the patient’s medical record This instruction does not apply to the directed donor unit ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 44 Splitting of Products • • CPT 86985 for splitting of a product is billable in addition to P9010 with the exception of the last aliquot Where a unit of blood is split specifically with the intent of transfusion but is not then transfused • The hospital may bill for the splitting the unit of blood (CPT 86985) The hospital may not bill the HCPCS code for the blood product The date of service must be the date on which the decision not to use the blood was made This determination must be indicated in the patient’s medical record ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 45 Irradiated Products • • • Do not bill separately for the irradiation of a product if a valid HCPCS code exists that defines the irradiated unit When a P-code is not defined by CMS for a specific irradiated product, it is appropriate to bill the HCPCS that most accurately represents the transfused product plus CPT 86945 for irradiation Where an irradiated unit is requested with the intent of transfusion but is not transfused, a charge for irradiation (86945) may be billed. However, the P-code for the unused product is not billable ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 46 Freeze and Thaw • • If a product-specific frozen or thawed P-code does not exist, OPPS providers may bill the appropriate freezing and / or thawing CPT code(s) in addition to the P-code that most accurately represents the blood product When a frozen / thawed product is not infused and is destroyed, the hospital may bill the appropriate freezing and / or thawing CPT code(s) but not the P-code for the unused blood product ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 47 Units of Service ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 48 ICD-9 CM Codes • • HIM typically assigns ICD-9 CM procedure codes for inpatient transfusions In 2011, there are five new ICD-9 CM codes that must be assigned to report ABO incompatibility reactions • 999.60 999.61 999.62 999.63 999.69 ABO incompatibility reaction, unspecified ABO incompatibility reaction not specified as acute or delayed ABO incompatibility with acute hemolytic transfusion reaction ABO incompatibility with delayed hemolytic transfusion reaction Other ABO incompatibility reaction Be aware that CMS considers these to be hospital acquired conditions (HAC) for which Medicare will not pay the additional costs associated with the complication ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 49 Auditing Tips • • Analyze documentation for the service Review claims for outpatient blood transfusion services • Blood bank can give you patient names, DOS, MR # Look at the claims You should see revenue code 0391 with CPT 364XX x 1 You should see revenue code 0390, 0392 or 0399 with a HCPCS P code • Billing units may be 1 or more You should see revenue codes 0380 with HCPCS P codes only if your facility operates a donor center or ‘buys’ blood Modifier BL must also appear on these claims ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 50 Review Audit Findings • Internal Audits • Do you know what the nurse auditors said about transfusion and transfusion related services? Have auditors cited issues relative to transfusions and / or transfusion related issues? Have the issues been investigated and remediated? External Audits HIGHLY RECOMMENDED Nurse auditors may not be familiar with blood bank procedures Blood bank managers are not always familiar with billing guidelines issued by CMS TAKE ACTION If you suspect something is wrong, it usually is ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 51 Assess Charge Code Usage • Look at volumes associated with charge codes for transfusions / blood administration, Charge codes assigned revenue code 0391 and CPT 36430, 36440, 36450, or 36455 • Look at charge lines used to report blood product processing Charge codes assigned revenue code 0390, 0392 or 0399 HCPCS ‘P’ code • Note the number; Note the departments that have volume Add up the units Make an assessment Assume that an outpatient will receive on average 2 units of blood. Assume that 5-7% of inpatient admissions will receive blood, and each of these patients will receive an average of 3 units of blood. Do the ratios indicate there is not a reason for concern, there is a potential problem, or the potential of a significant issue? ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 52 Summing It Up • • • Provide detailed CPT and Level II HCPCS codes in order to receive complete outpatient Medicare reimbursement Audit and Monitor to Identify charge capture disconnects Ensure that you have implemented coding structures for the following: Pre-transfusion workups such as blood typing, antibody screens and blood processing work (pooling of platelets, bone marrow / stem cell preparation) Cross-matches, transfusion reactions and antigen typing Blood and blood products Transfusions ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 53 THANK YOU FOR ATTENDING ©2013 PANACEA Healthcare Solutions, Inc. SLIDE 54
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