CMS has just issued the Proposed FY2023 Inpatient Rule in today’s Federal Register which when finalized will become effective October 1, 2022. One interesting item is that CMS is proposing to use National Drug Code (NDC) numbers to identify drugs eligible for New Technology Add-on Payments (NTAP) when used on Medicare inpatients. This is a change as previously CMS created unique ICD-10-PCS codes for each drug that received NTAP that were added to each claim by coders. Instead the NDC number would solely drive payment in FY2024 after a one year phase-in where both an NDC number or an ICD-10-PCS code would result in NTAP calculations.
One concern is whether pharmacy clinical and billing systems are capable of fully automating this process so that manual intervention is not required. We would like to hear from hospital pharmacists, particularly those with the big three eHRs (Epic, Cerner and Meditech), if your system will currently transmit an NDC number in the proper 5010 format to an inpatient claim. Let us know if the set-up is intuitive or complex. This can become complex as outpatient claims will still require a HCPCS code for payment and some drugs that are eligible for NTAP payments are also used on outpatients. Can your IT system handle both NDCs on inpatients and HCPCS codes on outpatients?
If you are a hospital pharmacy provider or affiliated with a Pharmacy IT system, please send in a description of how your system would work if this proposed rule becomes final. You can use the CONTACT US page of the website to submit your response www.pharmacyrevenuecycle.com/contact-us.
We’ll compile the responses and include them in a future newsletter.
Based upon your feedback, we’ll submit comments to CMS with your concerns and/or compliments on this proposed change for drug reporting on inpatient claims. The Federal Register version of the IPPS Proposed Rule was published today, May 10, 2022 and comments are due to CMS by June 17, 2022.
1. We want your feedback! Can your current IT system transmit NDC numbers on inpatient claims?
2. How complex is it to provide NDC numbers on inpatient claims for only drugs that qualify for NTAP reimbursement for a 2-3 year period?
3. What are some of the downstream complications that may occur when turning on NDC numbers for inpatient claims?
Our goal is simple; we’re taking complex information and making it practical.
Until our next edition, this is Maxie Friemel and Agatha Nolen providing you with tips for increasing your Pharmacy Revenue.