Medicare Billing Split between MD Office & Home IV Pharmacy
I have had an inquiry of the following and would appreciate your feedback: An oncology group has approached a home infusion pharmacy to provide the pump, supplies and nursing coverage for their chemotherapy patients. They prepare the drug and bill Medicare for the drug and an administration fee. Can the IV pharmacy bill Medicare for the pump and supplies with the physician billing for the other items?
Submitted by: Bruce E. Rodman, MBA
Response Summary
There were 9 Listserv responses to Bruce’s question. In summary, responses ranged from an absolute no, you cant’ bill for pump and supplies to Medicare Part B to yes we have had some success billing Medicare Part B only if the patient initiated the infusion in the physicians office and then went home. David Franklin summarized as follows:
As you indicate, physicians can and often do become DME suppliers. "Physician office" is actually one of the choices on the CMS 855s form that is used to apply for a DME provider number, and it allows physicians to bill the DMERCs (now MACs) for DME provided to their patients for home use - like crutches, wrist splints... and infusion pumps. In order to qualify for DMERC / MAC reimbursement, the infusion pump must be for home use. That is a common model in an oncology practice - for instance, a 5FU infusion administered continuously over two days. Under this scenario the physician office may bill for the rental of the pump just like any DME provider. But if the pump does not go home with the patient - i.e. a short term anti-infective or hydration case - it is considered incidental equipment that cannot be separately billed - like a stethoscope, otoscope, etc. If the equipment does go home and is for home use, the place of service (POS) would be 12.
Rock-Pond Analysis
Having a close working relationship with Physician Oncology practices is an important part of the success of many Home Infusion providers. Historically, Home Infusion providers have serviced Physician Oncology offices in the following ways:
- Sold drugs and supplies directly to Physician Oncology offices.
- Rented equipment – Infusion pumps and supplies to offices
- Compounded Patient Specific Chemotherapy and delivered for use in Physician Oncology offices.
- Opened Pharmacies and staffed (Pharmacist and Nurses) in larger Oncology Infusion Suites.
Nurturing the relationship with Physician Oncology practices can be a key strategy as the patients require many other Therapy services from the Home Infusion provider. The Home Infusion provider must be very aware of the cost of providing services to Physician Oncology practices and fully understand the legal and business ramifications of doing so.