FLASCO

CMS Pushes Modifier -JW Requirement to 2017

  • FLASCO
  • June 10, 2016

CMS Pushes Modifier -JW Requirement to 2017

Source: Medicare Compliance Watch

If CMS’ late April release of a change request requiring reporting of the previously optional modifier -JW (drug amount discarded/not administered to any patient) by July 1 seemed too sudden, the good news is many other providers—and the agency—agreed.

Due to stakeholder concerns about the quick turnaround—which would have required rapid coordination among billing, nursing, and pharmacy departments—CMS announced in this week’s Hospital Open Door Forum call that the requirement will be delayed to January 1, 2017.

The soon-to-be-updated MLN Matters® article 9603 required providers to:

  • Use modifier -JW for claims with unused drugs or biologicals from single-use vials or packages that are appropriately discarded (except those provided under the Competitive Acquisition Program for Part B drugs and biologicals)
  • Document the discarded drug or biological in the patient’s medical record when submitting claims with unused Part B drugs or biologicals from single use vials or single use packages that are appropriately discarded

The modifier -JW requirement is the agency’s latest attempt to rein in, or at least tabulate, Medicare drug costs and waste. This follows CMS’ controversial proposed test model to reimagine Part B drug payments.

Notably, CMS’ plans have yet to include drug manufacturers in a major way. The focus on providers has rankled some in the community, who have contributed to the more than 1,300 comments on CMS’ test model. A recent major study concluded that Medicare and private insurers waste nearly $3 billion on cancer drugs alone each year, in part due to manufacturers only offering doses too large for most patients—despite some companies offering smaller doses in international markets.

CMS announced that it would release an FAQ document to address stakeholder concerns surrounding the requirement, but providers can direct technical questions to hospital_odf@cms.hhs.gov for clarification. The delay will also give electronic health record vendors time to integrate methods for reporting the modifier into their software, according to CMS.

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