cost) if the per-day drug cost exceeds $120
and that it won't make a separate payment if
the drug costs $120 or less. The $120 thresh-
old holds true — unless CMS decides that a
drug "functions as a supply," in which case it
will package the drug into the facility fee,
regardless of the cost.
Is the drug on "pass-through" status?
To confuse you further, CMS will contin-
ue to reimburse separately for drugs that are
on "pass-through" status, regardless of
whether the drug functions as a supply. This
is great news — for the 24 to 36 months that
the drug is on pass-through.
A bit of background: Congress established
the pass-through provision in the Medicare
law to encourage advances in health care. As
an incentive, CMS pays providers above and
beyond the usual facility fee to use specifical-
ly designated "pass-through" drugs and
devices, letting you bill for such products out-
side of the bundled payment in which they
are used.
But it's a fleeting incentive. Statutorily, CMS
can only grant pass-through status for up to 3
years. When a drug's pass-through payment sta-
tus expires, so, too, does your ability to bill sep-
arately for the drug. While the "drugs-that-func-
3
M A Y 2 0 1 8 • O U T PA T I E N TS U R G E R Y. N E T • 1 7
9 Orchard, Suite 111
Lake Forest, CA 92630
www.optisurgical.com
info@optisurgical.com
Call AOI for Information
800.576.1266 or
949.580.1266
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