Can We Bill a Take-home Infusion Pump?

Q: Our infusion department provides drug administration services with a physician’s order. Sometimes, the protocol includes an infusion that will run for a day or two. Our nurses start the infusion on a pump that they send home with the patient. The patient returns to the department in a couple of days to have the infusion discontinued. The company that supplies our pumps wants to bill us for the use because they say they can’t bill the insurance company–especially Medicare. We don’t have a durable medical equipment (DME), license so we don’t think we can bill for the pump.

A: Actually, this is correct information. Drug administration services are provided “incident to” a physician service by your outpatient oncology department. The provision of the service is accomplished by the hospital department and all costs related to the service should be reported by the hospital department. The DME company has provided the pump to the facility for the provision of the services and is not providing the pump directly to the patient. There is no provision for a DME company to bill to the Medicare Administrative Contractor (MAC).

Medicare recently published MLN Matters SE1609, Medicare Policy Clarified for Prolonged Drug and Biological Infusions Started Incident to a Physician's Service Using an External Pump, and addresses this specific scenario. The patient is treated in the hospital outpatient department (HOPD) or physician’s office, requiring the providing entity to purchase the drug for the infusion. The infusion is initiated in the office/HOPD utilizing an external pump, with the patient leaving and then returning at the end of the prolonged infusion period. Under sections 1862(s)(2)(A) and (B) of the Social Security Act, Medicare pays for medically necessary drugs and biologicals that are not usually self-administered when furnished incident to a professional service.

While CMS does not provide specific guidance to providers regarding coding, they note that the drug administration services would include the costs of the equipment required to furnish the service. This equipment is not separately billable as DME because the service is provided and paid under the incident to benefit. Based on the information in SE1609, the service is billed to the MAC by the providing physician office or HOPD. The “MAC may direct use of a code described by CPT or an otherwise applicable HCPCS code for the drug administration service. If necessary, the MAC may direct use of a miscellaneous code for the drug administration if there is no specified code that describes the drug administration service that also accounts for the cost of equipment that the patient takes home” for the duration of the infusion.

Each provider should be sure that the cost of utilizing the pump is included in the charge for the prolonged drug administration service to insure that accurate cost information is reported to CMS.

Editor’s note: Denise Williams, RN, CPC-H, senior vice president of revenue integrity services at Revant Solutions, in Fort Lauderdale, Florida, answered this question.