Billing for administration of free samples of contrast enhancing agent

Q.

How should I bill for a procedure when using no cost/free samples of a contrast-enhancing agent?

A.

The Medicare Claims Processing Manual, Chapter 32, Section 67.2 states:

For OPPS claims, when a drug is provided at no cost claims processing edits prevent drug administration charges from being billed when the claim does not contain a covered/billable drug charge. Therefore, for drugs provided at no cost in the hospital outpatient department, providers must report the applicable drug HCPCS code and appropriate units with a token charge of less than $1.01 for the item in the covered charge field and mirror this less than $1.01 amount reported in the noncovered charge field. Providers must also bill the corresponding drug administration charge with the appropriate drug administration CPT^® or HCPCS code.

Our interpretation of CMS guidance is that both the procedure code and HCPCS code for the drug should be included in the chargemaster and billed as a standard procedure. However, the charge associated with the free or sample drug should be less than $1.01.

For claims being billed in physicians’ offices, according to the Medicare Claims Processing Manual, Chapter 32, Section 67.1: Practitioners typically should not bill for no-cost items as there is no non-covered charges field on the claim and there are also no system edits in place to require providers to do so.

As always, we recommend our customers consult with their internal revenue cycle and legal teams as to how their sites handle billing and coding for free samples of contrast drugs.