Since 2017 facilities have been using Modifier JW for reporting the wastage of a drug from a single-use vial or package prior to administration.
Due to the fact that modifier JW was not being used correctly if at all, CMS (Centers for Medicare and Medicaid Services) provided clarification and education on the proper use of modifier JW as well as instructions for the use of a new modifier to be used starting July 1, 2023, Modifier JZ.
As we see clearly in their instructions, it is more than merely applying these modifiers, but the verification through documentation of their validity so that the true picture can be seen as to proper reimbursement owed to a provider or facility.
Identify the correct modifier
First, we need to identify which modifier is applicable in a given scenario. In order to do so, we need to define each modifier.
Modifier JW as defined by CMS is to be used on a claim to indicate the amount of the drug discarded that would be paid. According to the discarded drug policy, this modifier should be used only for services where a single-dose container is involved.
Modifier JZ as defined by CMS is to be used to indicate that no amount of drug was discarded and will not be paid. This modifier is applicable only for claims that bill for single-dose container drugs.
In essence, we should be looking closely at our understanding of Modifier JW as to its proper use. When we understand the purpose of identifying discarded drugs, it becomes clear that modifier JZ would follow the same concept when no wastage occurs.
Now since the key to these modifiers lies with a single-dose vial being used the question might come up, How can I tell if the drug dispensed was a single-dose vial or a multi-dose vial? Keep in mind that the HCPCS code description does not include single or multi-dose vials.
So then for a coder and or biller to be accurate and bill out timely the documentation should be clear that it is a single vs multi-dose vial being used.
A Single-Dose vial will be labeled as such by the manufacturer and will usually not have an antimicrobial preservative. These are intended for, you guessed it a single patient only. According to the CDC, there have been multiple outbreaks resulting from healthcare workers using these for more than one patient. Learn more
A Multi-Dose vial will have more than one use available and is labeled as such by the manufacturer. These of course will usually contain an antimicrobial preservative. While it is recommended that they be reserved for a single patient, if they are used for additional individuals then they need to be stored in a dedicated clean environment. Learn more
Please ensure that you have efficient workflows in place and excellent communication with the clinician documenting so you can validate each drug with accurate information such as the name of the drug, dose, NDC, and other important manufacturer information.
Documentation and Compliance
Coders and billers can identify the proper use by understanding how a particular drug is labeled and if it is documented correctly. Accurate documentation to support correct drug billing should follow a specific checklist:
- Is there a physician order for the medication(s) to be administered indicating the physician’s signature, date, dose, route, and frequency?
- Has the medication administration record (MAR) and/or infusion flowsheet been checked for the quantity administered with the dose, route, and frequency administered?
- Is there documentation of drug wastage and how much?
- Does documentation support the diagnosis for the drug administered based on signed physician notes, diagnostic tests, or laboratory testing?
- Have you reviewed payer policies such as LCD or NCD?
- If there are known coverage issues, has the patient signed an ABN form per Medicare requirements?
- Have you verified a signature log or attestation for any missing or illegible signatures?
- Is the NDC drug code documented and verified as indicated on the vial that was administered?
There are many situations to consider but overall if you understand the purpose and intent of modifier JW and JZ, with the required documentation elements, then you can ensure a successful billing process with minimal denials. Talk to an expert in billing and coding for a breakdown of specific scenarios, or schedule a quarterly audit with the team at Oncospark. Email auditing@oncospark.com