Participants in the 340B program

dwilliamsrsi

Take a close look at the OPPS final rule, but also the recent FAQs published by CMS.  (December 13).  The requirement for the JG modifier for drugs with status indicator K (separately payable) was noted in the final rule,  However, the sub-regulatory guidance in these FAQs notes that modifier TB is required to be reported on status indicator G (pass-through) drugs.  They note that both modifiers are mandatory.  For CAH's they must report modifier TB for information purposes, but there is no payment reduction as they are paid based on cost. We need to pay close attention to these instructions as time is growing short until January 1.  Below is the link to the FAQ document.

https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HospitalOutpatientPPS/Downloads/Billing-340B-Modifiers-under-Hospital-OPPS.pdf

jugnashah

The sub-regulatory guidance definitely calls for additional uses of modifier TB that I think has caught most people by surprise.  CMS is definitely on a mission to collect data and expects providers to "get it right" because they keep saying that if provider systems and/or processes are not ready then they should hold claims.  I'm curious to see what happens with the AHA lawsuit/hearing on Dec 21st.  Maybe everything will get put on hold.