Q&A: CPT coding for infusions with no documented stop time

July 27, 2018
Medicare Web

Q: How would you report an infusion service with no documented stop time?

A: CMS doesn’t provide specific guidance about what should or should not be reported. Providers should check to see if their Medicare Administrative Contractor (MAC) has a policy about this and if so, follow it. If your MAC has no policy on this, then adhering to CPT guidelines is the most appropriate course of action.

The CPT Manual states that an infusion of 15 minutes or less must be reported as an IV push injection. If you have an order for an infusion and the start time but no stop time is documented, then you can assume it was an infusion of 15 minutes or less.

However, MACs have their own guidelines for reporting infusions without documented stop times. Some MACs simply reiterate the CPT Manual and indicate that an IV push can be reported. Others say an infusion can be reported only if it can be determined from the documentation that the service was more than 15 minutes in length.

Healthcare organizations have weighed in on the sort of time documentation needed to support billing for drug administration services. The American Medical Association (AMA) recommends that providers document start and stop times but does not say this documentation is required.

According to CMS, there is an expectation that hospitals will document time; otherwise, CMS has a difficult time understanding how services would be billed appropriately. There is no statement about stop times being required; however, it is implied that this is the best practice to ensure appropriate billing.

Per the Medicare Claims Processing Manual, Chapter 4, codes should be reported in accordance with CPT guidelines. CPT instructions are to use the actual time over which the infusion is administered to the beneficiary for time-specific drug administration codes.

MACs use different language such as “it would be best to report start and stop times,” and “time-based codes must be documented with start and stop times.” Again, this language implies that reporting both start and stop times is the best practice to ensure billing compliance.

Editor’s Note: Jugna Shah, MPH, president and founder of Nimitt Consulting, answered this question during HCPro’s virtual workshop, “Injections and Infusions Live!: Practical Training Through JustCoding’s Virtual Workshop.”

This answer was provided based on limited information. Be sure to review all documentation specific to your own individual scenario before determining appropriate code assignment.

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