CMS Releases January 2015 Update of the Ambulatory Surgical Center (ASC) Payment System

Recently, CMS released an update for ASCs that will be submitting claims to Medicare Administrative Contractors in 2015 for services to Medicare beneficiaries. Please see below for the specifics on the clarifications and updates:

Billing for Corneal Tissue

CMS reminds ASCs that according to the “Medicare Claims Processing Manual,” Chapter 14, Section 40- Payment for Ambulatory Surgery, corneal tissue is paid based on acquisition cost or invoice. To receive cost-based reimbursement for corneal tissue acquisition, ASCs must bill charges for corneal tissue using HCPCS code V2785.

Coding Guidance for Intraocular or Periocular Injections of Combinations of Anti-Inflammatory Drugs and Antibiotics

CMS notes that intraocular and periocular injections of combinations of anti-inflammatory drugs and antibiotics are being used with increased frequency in ocular surgery, primarily cataract surgery. One example of combined or compounded drugs includes triamcinolone and moxifloxacin with or without vancomycin. These combinations may be administered as separate injections or as a single combined injection. Because such injections may obviate the need for postoperative anti-inflammatory and antibiotic eye drops, some refer to this as “dropless cataract surgery.”

CMS provides specific guidance below:

  • The CY2015 National Correct Coding Initiative Policy Manual states that injection of a drug during a cataract extraction procedure is not separately reportable. Specifically, no separate procedure code may be reported for any type of injection during surgery or in the perioperative period. Injections are a part of the ocular surgery and are included as a part of the ocular surgery and the HCPCS code used to report the surgical procedure.
  • According to the Medicare Claims Processing Manual, Chapter 17, the compounded drug combinations described above and similar drug combinations should be reported with HCPS code J3490 (unclassified drugs), regardless of the site of service of the surgery, and are packaged as surgical supplies in both the Hospital Outpatient Department (HOPD) and the ASC. Although these drugs are a covered part of ocular surgery, no separate payment will be made. In addition, these drugs and drug combinations may not be reported with HCPCS code C9399.
  • According to the Medicare Claims Processing Manual, Chapter 30, physicians or facilities should not give Advance Beneficiary Notices (ABNs) to beneficiaries for either these drugs or for injection of these drugs, because they are fully covered by Medicare. Physicians or facilities are not permitted to charge the patient an extra amount (beyond the standard copayment for the surgical procedure) for these injections or the drugs used in these injections because they are a covered part of the surgical procedure. Also, physicians or facilities cannot circumvent packaged payment in the HOPD or ASC for these drugs by instructing beneficiaries to purchase and bring these drugs to the facility for administration.