Knowledge Base Article

Q:
What does Medicare expect from providers concerning limiting drug wastage? For example, if a chemo drug comes in two sizes of single-dose vials, 100 mg and 160 mg and the patient’s dose is 237 mg, could we use three 100mg vials with a wastage of 63 mg, or must we use one 100mg and one 160mg vial for the least amount of wastage (23mg)? 

A:

The Medicare Claims Processing Manual, Chapter 17, section 40 states, “The CMS encourages physicians, hospitals and other providers and suppliers to care for and administer to patients in such a way that they can use drugs or biologicals most efficiently, in a clinically appropriate manner.”

Medicare is generally not concerned if you have to jump through extra hoops in order to comply with their guidelines.

Since…

• This drug is separately reimbursed by Medicare
• Medicare has done targeted reviews of some of the other chemo drugs specific to waste issues
• Medicare has instructed hospitals how to report drug waste

 ……MMP recommends you try to minimize waste, even if it involves extra steps.

If you have only the 100 MG dose vials available, then you use what you have. In this case, you are allowed to bill the waste as long as there is not another patient getting the same drug for which the unused portion could have been used.

If you are reviewed by a Medicare reviewer, and they question your billing, you might have to provide invoices, or other documentation proving why you billed as you did.