By Rick Collins
Has there ever been a more exciting and yet turbulent time for medical billers? For those billing end-stage renal disease (ESRD) claims, the changes have been coming fast and furious with one major change after another. In many respects, the changes made to ESRD billing have been at the forefront of changes being made to billing and reimbursement in the rest of the health care industry. Bundled rates and quality improvement plans are being applied to specialties and looks to be the way of the future.
In this month’s column we will address numbing agents prior to needle sticks, a helpful Centers for Medicare & Medicaid Services (CMS) website for ESRD billers, and an explanation as to why people react to e-mails so differently than what you may have intended.
NUMBING CREAMS AND SPRAYS
Q. I was reviewing your comments about numbing creams and sprays in your previous columns and wanted some additional details. Our clinics have started keeping a small supply of the cream to use for patients. However, to be effective, they really need to come in early to have the cream applied for the numbing effect to take place. No one really wants to do that. If we get tubes of cream in, can we dispense these to patients? I’m thinking we should not because we are not a pharmacy and should not be in the business of dispensing medications.
Also, on the topic of lidocaine sprays, is this something that Part D plans are continuing to cover or are they part of the ESRD Bundle? The spray is more effective as a fast-acting anesthetic so it can be used just before the needle insertions.
A. Thanks for your questions. You are right to be concerned about dispensing a prescription cream to patients. I do not know in which states your facilities are located, but the pharmacy laws in many states prohibit the dispensing of prescriptions from any entity that does not have a pharmacy license. Thus, if you want those patients to have the cream to take home and apply prior to coming in for a dialysis treatment, you could have them obtain it from a licensed pharmacy and ask them to put it on before they come in.
However, I’m sure it would be somewhat hit-and-miss as to whether patients remember to put it on or not.
Numbing sprays and creams are included in the composite rate according to Section 30.4.1 of the Medicare Benefit Policy Manual, Chapter 11, and are not available as a Part D benefit. Section 30.4.1 provides a list of drugs included in the ESRD benefit and specifically mentions “local anesthetics” and “lidocaine.”
So what can you do to provide a numbing agent to your patients without running afoul of prescription medication laws and/or incurring a potentially significant increase in cost?
Several facilities have purchased over-the-counter numbing sprays for use with their patients. Some nurses have told me these sprays don’t work as well as some of the expensive creams while others said their patients, did not notice a lot of difference in effectiveness. As you mentioned, the sprays are fast-acting and can be used just before the treatment so it would make sense to me that your facilities could save money, avoid pharmacy regulations, and help your patients by simply purchasing non-prescription numbing sprays. Of course, this is my opinion based on the information I have so please make any final decisions based on the best interest of your patients in conjunction with your facility staff and physicians.
Readers: the topic of numbing creams and sprays continues to be of concern in the ESRD industry. How has your dialysis program handled this issue? If you changed your numbing agent, are your patients as happy with the new agent as they were the old? Has your dialysis program been affected by increased costs related to this issue? Please send your comments and experiences to me at rcollins@sceptremanagement.com.
