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Updates to Immunosuppressive Guidance for Inpatient Coders

Inpatient facilities (for example, hospitals) are responsible for providing drugs during a beneficiary’s inpatient stay. However, once the Beneficiary has returned home, Part B suppliers (including pharmacies) provide the Immunosuppressive drugs, and the DME MACs make the payments for Part B covered immunosuppressive drugs. 

In certain cases, a beneficiary who has received a transplant does not return home immediately after discharge. In order to ensure timely beneficiary access to prescribed immunosuppressive medications at the time of discharge, suppliers may deliver the initial prescriptions of a beneficiary’s immunosuppressive drugs to an alternate address, such as the transplant facility or alternative location where the beneficiary is temporarily staying, for example, temporary housing, instead of delivering the drugs to the patient’s home address. 

Note that this is an optional, not mandatory, process. If the supplier ships immunosuppressive drugs to an alternate address, all parties involved, including the beneficiary and the transplant facility, must agree to the use of this approach. All other applicable Medicare and DME MAC billing requirements continue to apply. This provision is limited to prescriptions that will be billed on the first claim that the supplier submits for the beneficiary after the beneficiary is discharged from an inpatient facility.

The following conditions also apply:

 • The immunosuppressive drug must be medically necessary on the date of discharge; that is, there is a valid prescription for an immunosuppressive drug that is reasonable and necessary and is clinically required to be available no later than the date of discharge for home use. 

• Early and/or direct delivery to the transplant facility does not change the inpatient facility’s responsibility to provide all immunosuppressive drugs that the beneficiary requires during their entire inpatient stay. 

• The supplier must not: 

o Mail, or otherwise dispense the drugs any earlier than 2 days before the beneficiary’s anticipated discharge date. (It is the supplier’s responsibility to confirm the beneficiary’s discharge date.) 

o Submit a claim for payment prior to the beneficiary’s actual date of discharge. 

o Claim payment for additional costs that the supplier incurs in ensuring that the immunosuppressive medications are delivered to the alternative location. Additionally, the supplier also must not bill Medicare or the beneficiary for redelivery if it is necessary. This new guidance may be used with the early delivery provision already described in Section 80.3.3, and all other applicable Medicare and DME MAC billing requirements continue to apply.  

Reference:

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM11072.pdf



This post first appeared on Interventional Radiology Medical Coding - Learn How To Code, please read the originial post: here

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Updates to Immunosuppressive Guidance for Inpatient Coders

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