Kim and Tess, thanks for brining this us, because I completely missed this new criterion.
So now that I have had the joy of reading this lovely new requirement, and yes thanks Tom for the link, this is where I have it in my mind (if anyone sees differently please opine):
- The process of tracking and reporting wasted drugs is at best a break even scenario..
- It appears, however, that we now have to do it.
- The intent is so Medicare can go after the drug manufacturers for a refund "refundable single dose" terminology.
- While the "refundable singe dose" does not apply to radio and contrast agents, that DOES NOT mean it doesn't apply to the JZ/JW implementation.
- From CMS:
- Then trying to ascertain what "drugs" are considered "single dose" is a especially fun. Best I could do was go to https://labels.fda.gov/packagecode.cfm, look up the NDC number, click on the drug and look for the package labeling.
- Did I over complicate this?????
- While tempted to just put JZ on each code, that appears to be against the intent of these regulations.
I would love someone to tell me I'm wrong!!!!!!!!!!!!!!!!!!!!!!
Any comments insight would be appreciated.
------------------------------
Douglas G. Kraus, CPA
Chief Financial Officer
South Texas Radiology Group, P.A.
------------------------------
Original Message:
Sent: 06-22-2023 10:32
From: Thomas Greeson
Subject: JZ/JW Modifier Changes
See this response to a comment on page 69724 in the final 2023 MPFS rule.
https://www.federalregister.gov/documents/2022/11/18/2022-23873/medicare-and-medicaid-programs-cy-2023-payment-policies-under-the-physician-fee-schedule-and-other#p-2518
"Response: We agree with the commenter and clarify that even if a drug is excluded from the definition of refundable single-dose container or single-use package drug (and not subject to refunds), for example, multiple source drugs, claims for such drugs furnished from a single-dose container are still required to use the JW and JZ modifiers in accordance with the policy we are finalizing in this final rule."
The rule contains an "imaging" exclusion for manufacturers reporting obligations to CMS. Despite that, the JZ modifiers is still required. But note that the use of the modifier is limited to the circumstance of separately payable drugs under Medicare Part B. Most payment for radiology procedures with contrast paid via the MPFS have the cost of the drug bundled into the underlying payment.
A complicated rule, for sure.
Thomas W. Greeson
Partner
Life Sciences Health Industry Group
He/Him/His
tgreeson@reedsmith.com
D: +1 703.641.4242
M: +1 703.517.0495
Reed Smith LLP
7900 Tysons One Place
Suite 500
McLean, VA 22102-5979
T: +1 703 641 4200
F: +1 703 641 4340
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Original Message:
Sent: 6/22/2023 6:59:00 AM
From: Tess Yee
Subject: RE: JZ/JW Modifier Changes
Good morning!
This is my first time dealing with JZ/JW and I understand the contrast exclusion, but have been unable to find guidance on some other drugs/biologicals we use (Kenalog, Dexamethasone, Albumin). I've tried to research the NDC numbers but did not see information to help me determine if these are considered 'single use' & therefore subject to the modifier requirements.
Does anyone have advice on how to determine single v multi-use status?
Appreciate any assistance!
Regards,
Tess
------------------------------
Tess Yee
Coding Team Lead
Delaney Radiology
Wilmington NC
(910) 341-1881
Original Message:
Sent: 06-21-2023 12:52
From: Kim Smiley
Subject: JZ/JW Modifier Changes
Hi Hulah,
So far according to what I have read, contrast agents are the only exclusion from this new policy.
Thanks!
Kim Smiley, CPC, RCC (She/Her/Hers)
Coding Manager
ph: (317) 328-7256 | fax: (317) 715-9955
kim@northwestradiology.com
Original Message:
Sent: 6/21/2023 11:56:00 AM
From: Hulah Gorby
Subject: RE: JZ/JW Modifier Changes
Hello,
I have been out of touch with Radiology for a while but am now back at it. I feel like i'm trying to catch up on all I missed while I was gone. We have on imaging center that does CT Pet scans. We use A9552 or A9596 and the clinic told me they are all single use vials with no waste. Do we use JZ on these?
What about contrast for CT and MRI's? I was told the CT exams are single use, no waste. Do they need JZ mod? Our MRI tech said they often use a 15 mL bottle but only give 12ml and discard the rest. Do you bill the 3ml with JW? Thank you for your help.
------------------------------
[Hulah] [Gorby] [CPC, CPMA]
[Coding Supervisor]
[Custom Data Services, Inc]
[Merrillville] [IN]
[219-769-1670]
Original Message:
Sent: 06-21-2023 10:08
From: Christina Negron
Subject: JZ/JW Modifier Changes
Hey Kim,
We have already implemented these changes.
We were lucky enough to get some automation assistance from our RIS system.
I'm happy to discuss with you.
Thanks,
Christina Negron, CPPM, CPC, RCC, CIC, CIRCC
Revenue Cycle Manager
Radiology Associates of Venice and Englewood, PA
941-486-3483 Direct
239-209-4787 Cell
941-484-9235 Fax
CNegron@RaveRad.com
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Original Message:
Sent: 6/21/2023 10:05:00 AM
From: Kim Smiley
Subject: JZ/JW Modifier Changes
Hello,
With the upcoming billing requirements for single dose packaged drugs, is anyone considering changing their billing practices? The amount we are reimbursed is so minimal it almost seems not worth the effort to continue billing for these drugs in an OBL setting.
The reporting requirement will certainly pose a burden with little financial gains.
Are there some drugs that should be considered "worth the effort"?
Thank you in advance,
Kim Smiley, CPC, RCC (She/Her/Hers)
Coding Manager
ph: (317) 328-7256 | fax: (317) 715-9955
kim@northwestradiology.com
