Billing Drug Waste with C9399

Published 06/04/2020

The Centers for Medicare & Medicaid Services (CMS) encourages physicians, hospitals and other providers to provide injectable drug therapy incident to a physician’s services in a fashion that maximizes efficiency of therapy in a clinically appropriate manner. If a physician, hospital or other provider must discard the unused portion of a single-use vial or other single-use package after administering a dose/quantity appropriate to the clinical context for a Medicare beneficiary, the program provides payment for the entire portion of drug or biological indicated on the vial or package label. This is true even when the drug or biological does not have specific HCPCS coding assignment yet and can be billed as C9399.

When billing for drug waste, providers should bill one line of C9399 for the amount of the drug administered to the Medicare beneficiary and one line of C9399 with the JW modifier for the amount of drug waste. The amounts of the drug being billed under each line should be clearly explained in the Remarks of the claim.

All of the other requirements for billing C9399 must be met. This includes billing C9399 as 1 unit and providing the NDC of the drug being billed.

If less than a complete single-use vial is administered at the time of service, the drug wastage must be documented in the patient’s medical record with the date, time and quantity wasted. The amount billed as 'wastage' must not be administered to another patient or billed again to Medicare. All procedures for drug storage, reconstitution and administration should conform to applicable Federal Drug Administration (FDA) guidelines and provider scope of practice.

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