Compliance: Waste Not, Want Not Where Drugs Are Concerned, Says OIG

Why This Topic Matters

Improper billing for discarded drug amounts can create overpayments, audit exposure, and refund obligations. The article is relevant to practices that administer injectable drugs and need to align documentation, scheduling, and claim reporting with Medicare compliance expectations.

Article Sections

1. OIG audit findings on multi-use drug vial billing

   Discusses an OIG review of claims handling for a multi-use oncology drug and the resulting compliance concerns. Covers the general billing accuracy issue and the role of the Medicare contractor in payment review.

2. Scheduling and documentation considerations for multi-use vials

   Describes operational considerations intended to reduce drug wastage and support accurate claims. Includes broad guidance on record support and aligning billed amounts with administered amounts.

3. Single-use vial rules and reporting waste

   Contrasts billing considerations for single-use vials with the multi-use vial discussion. Notes that some payer policies may involve separate reporting of discarded amounts and a related modifier.

4. Resources

   Lists external references cited by the article for readers who want the underlying OIG and CMS contractor materials.