Pharmacy Compliance Question of the Week
July 26, 2010
Question:
Last week’s question related to incident-to and self-administered drugs. Can you provide more information about how CMS defines “self-administered”?
Answer:
In transmittal R123BP (April 30, 2010), the Centers for Medicare & Medicaid Services (CMS) furnished Medicare contractors with updates to the Medicare Benefit Policy Manual relating to determining self-administration of drug or biological. In that transmittal, CMS explains that the update allows for other routes of administration besides injections to be considered as not usually self-administered. Below is a direct quote from the related provider-information memo MM6950.
“The Medicare program covers drugs that are furnished ‘incident to’ a physician’s service provided that the drugs are not usually self-administered by the patients who take them. … The term “administered” refers only to the physical process by which the drug enters the patient’s body. It does not refer to whether the process is supervised by a medical professional (for example, to observe proper technique or side-effects of the drug). Injectable drugs, including intravenously administered drugs, are typically eligible for inclusion under the ‘incident to’ benefit. With limited exceptions, other routes of administration (including, but not limited to, oral drugs, suppositories, and topical medications) are considered to be usually self-administered by the patient.”
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