Q&A: Reporting drug administration that crosses midnight

Q: How should drug administration services be reported when they cross the midnight hour?

A: The number one issue related to this is, “Would coders record two initial services, one for today’s date of service and one for the next day?”

The answer to this can be found in CMS Transmittal 1702 and the Medicare Claims Processing Manual.

Transmittal 1702, dated March 13, 2009, states:

Drug administration services are to be reported with a line item date of service on the day they are provided. In addition, only one initial drug administration service is to be reported per vascular access site per encounter, including during an encounter where observation services span more than one calendar day.

This makes it clear that you report codes for the entire encounter and report the date that the service was rendered. This means you may see multiple lines of the same CPT code with different dates of service. For instance, if an infusion is administered today and goes across the midnight hour.

Multiple initial service codes should not be reported, unless two vascular access sites or infusions are stopped, and IV access is removed and restarted later.

One follow-up question I get with this is “What if I get an edit?” And what I ask in response is “What is causing that edit?” Medicare has made clear that this is a continuous encounter and you should not report two initial services.

For example, suppose a patient comes to the ER on January 20 and IV hydration is started at 10 p.m. and continues until 6:30 a.m. on January 21. The patient also received an IV push of morphine at 10:20 p.m. on January 20 and again at 2 a.m. on January 21.

The following CPT codes would be reported:

• 96374, therapeutic, prophylactic, or diagnostic injection; intravenous push, single or initial substance/drug (administered on January 20)
• Add-on code 96361 x2, intravenous infusion, hydration; each additional hour (administered on January 20)
• Add-on code 96361 x6 (administered on January 21)
• Add-on code 96376 therapeutic, prophylactic, or diagnostic injection; each additional sequential intravenous push of the same substance/drug provided in a facility (administered on January 21)

Apply the drug administration hierarchy for the entire encounter. You must have one initial service for all the services unless you meet the expectations (stated above). Never report a second initial service solely because you crossed the midnight hour. 

Editor’s Note: Jugna Shah, MPH, president and founder of Nimitt Consulting, and Valerie A. Rinkle, MPA, lead regulatory specialist and instructor for HCPro's Revenue Integrity and Chargemaster Boot Camp®, answered this question during the HCPro webinar, “2018 Injections and Infusions Coding: CMS’ New Packaging Policies and Reimbursement Implications.”