General Question for the Week of March 19, 2018

General Compliance Question of the Week

Question:

One of our physicians sent a patient to the outpatient department to have a PICC line inserted (36568 or 36569) and have the first round of therapeutic medications (96365, 96366, 96367, 96368) on the same day. Can you please tell us if the insertion of a PICC line and the administration of the antibiotic drug can be charged on the same day with a modifier of 59 or XU?

Answer:

The clinical practice for use of PICC lines and drug infusions is commonplace. The coding policy for intravenous infusions/injections and vascular access was created to ensure that integral/component services are not being separately reported and paid. Medicare states that placement of peripheral vascular access devices and catheter access is not separately reportable.

However, the National Correct Coding Initiative (CCI) edits are built to require a modifier for the infusion services rather than the placement of the PICC. These guidelines currently do not make a distinction between placement of a PICC in one hospital department and patient receiving infusion services in another hospital department on the same date of service. For this scenario, the hospital may report the placement of the PICC by the applicable department and report the applicable drug administration code(s) with modifier 59 or XU (unusual non-overlapping service) by the other department.

When the PICC is inserted/placed by the same department (cost center), then the intravenous infusion/injection is considered a component of the procedure and not separately billable.

The NCCI Policy Manual for Medicare Services includes a guideline about this in Chapter XI, section B, item number 4. See https://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/index.html.

Disclaimer: Every reasonable effort was made to ensure the accuracy of this information at the time it was published. However, due to the nature of industry changes over time we cannot guarantee its validity after the year it was published.