It’s Groundhog Time Again… C9399 and Drug Billing with Waste Again…

In a previous newsletter, we addressed the efforts surrounding billing for drug waste and the importance of applying the JW modifier. Separately, we discussed the importance of billing a FDA approved drug with a C9399 that has not been assigned a permanent HCPCS. Though it seems intuitive to apply the waste billing logic to a drug coded with C9399, most EMRs are unable to perform this cleanly and may leave you with an area of revenue leakage. 

First, let us review the elements required to bill for C9399 and drug waste. 

✅ HCPCS code C9399 is billed with a quantity of “1” (one) on the claim which is essentially a placeholder.

✅ HCPCS C9399 must also report the National Drug Code (NDC) and quantity administered (expressed in the NDC unit of measure).

✅ Detailed information including, C9399, drug name, NDC, and amount administered, should be entered into the NOTES/REMARKS on the claim.

✅ Discarded waste from separately payable single-dose vials must be recorded in the patient’s medical record. 

✅ A separate charge line on the claim with the JW modifier should be reported when billing waste for drugs with a permanent HCPCS (not C9399) unless the payer has alternative instructions.

✅ CMS does not allow for fractional billed units in which case the administered dose may need to be rounded up, and the wasted portion should not exceed the total billed units within the vial uses. 

The majority of Medicare Administrative Contractors (MAC) do not provide further guidance on how they would like to see the claim when waste is generated from a C9399 except Palmetto GBA. Thus, this leaves you with two options:

Option 1: Using one charge line only, report the HCPCS C9399 with a quantity of 1. The NOTES/REMARKS section within a claim should include both the administered and wasted portion reported with the JW modifier. 

Option 2 (according to Palmetto): Use 2 charge lines, one reporting C9399 reflecting the amount of drug administered to the patient and one line representing the wasted portion including the JW modifier. Both the administered and wasted amount should be clearly explained in the NOTES/REMARKS section on the claim. 

Shout Outs!

1. Pharmacy teams. Ensure waste is documented in the patient’s medical record if you plan to bill for the waste. 
2. Billing teams. Validate that there is a process to capture all drugs with C9399 and record detailed information regarding the administered and wasted portion of the drug in the NOTES/REMARKS section.
3. Revenue Integrity. Payment on a C9399 is a manual process by the MAC and it is important to validate that this is completed accurately for the dose and wasted portion.
4. Pharmacy teams. Monitor the 340B accumulation (if applicable). Depending on how your extracts pull from your EHR, the waste portion may be omitted.

Thanks to our readers and listeners for asking these unique questions!