US Medical Billing
Specialty billing guide

Rheumatology billing

The question that decides most rheumatology drug claims is not what this patient needs. It is what more than half of all Medicare beneficiaries taking this drug do with it. The Benefit Policy Manual defines "usually self-administered" as more than 50 percent of the time across the whole beneficiary population -- and instructs contractors to presume, absent evidence to the contrary, that a subcutaneous injection is self-administered.

  • "Usually" means more than 50 percent of all Medicare beneficiaries who use the drug
  • Subcutaneous injection is presumed self-administered; intravenous and intramuscular are presumed not
  • The determination is made per indication, then weighted by each indication's share of total use
  • Bone mass measurement has its own gate: 23 months since the month of the last one

This is an educational guide to how billing works for rheumatology — its workflow, coding, and payer considerations. It is general information, not a statement that US Medical Billing serves this specialty, and not billing, coding, or legal advice.

What makes rheumatology billing distinct

Medicare covers drugs furnished incident to a physician's service provided they are not usually self-administered by the patients who take them. The Benefit Policy Manual interprets that phrase, and the interpretation is the thing worth knowing: for the purposes of the exclusion, "usually" means more than 50 percent of the time for all Medicare beneficiaries who use the drug. If a drug is self-administered by more than half of them, it is excluded and the contractor may not make any payment for it. Whether a particular patient could manage the injection does not enter into it.

The determination is also made a drug at a time rather than a claim at a time, and in two steps. Contractors make a separate determination for each indication, then determine each indication's relative contribution to total use and take a weighted average to reach one overall answer. The manual's own example has a drug with three indications: not self-administered for the first, self-administered for the second and third, with the first making up forty percent of use and the others thirty each -- and the drug therefore counts as usually self-administered. A rheumatology indication can lose to the arithmetic of indications it has nothing to do with.

Route sets the starting presumption, and it is the presumption that puts rheumatology on the wrong side of the line so often. Absent evidence to the contrary, contractors presume that drugs delivered intravenously are not usually self-administered, that drugs delivered by intramuscular injection are not usually self-administered, and that drugs delivered by subcutaneous injection are self-administered. The subcutaneous presumption is rebuttable by examining the condition and the frequency: an acute condition makes self-administration less likely, and a drug given once a month is less likely to be self-administered than one given weekly or more often. The manual defines an acute condition for this purpose as one that begins over a short time period and is likely to be short, and states that a course of scheduled injections lasting less than two weeks is acute regardless of frequency or route.

Two further rules narrow the question in ways that surprise people. "By the patient" means Medicare beneficiaries as a collective whole, counting the patients themselves and not spouses, friends or other caregivers -- and beneficiaries who could not self-administer any drug at all because of an unrelated condition are left out of the population the determination is based on, while beneficiaries with a less severe stage of the same kind of condition are counted in. And each contractor makes its own determination, so the same molecule can sit inside the benefit in one jurisdiction and outside it in another.

The specialty's other signature service is gated by a different kind of arithmetic. 42 CFR 410.31 covers bone mass measurement when it is ordered by the treating practitioner following an evaluation of need, performed under the appropriate level of physician supervision, and furnished to a beneficiary in one of five named categories -- one of which is defined by a dose: an individual receiving, or expecting to receive, glucocorticoid therapy equivalent to an average of 5.0 mg of prednisone or greater per day for more than three months. The frequency standard is not "every two years". Medicare may cover a measurement if at least 23 months have passed since the month the last one was performed.

How rheumatology billing flows

The decisive work happens before the drug is ordered, because by the time it has been given the benefit it falls under is already settled.

Routing the therapy to the right benefit

Whether a drug is a medical benefit given in the office or a pharmacy benefit filled for the patient is decided by the self-administration determination, not by the practice. The answer changes who bills, who is paid and what the patient owes.

Common operational challenges

The recurring difficulties come from decisions that are made outside the practice and change without the practice being told.

  • A coverage answer with no patient in it

    The self-administration test is population-level and drug-level. Nothing in the record of the patient in front of you moves it, which makes it a very hard denial to appeal on clinical grounds.

  • The same drug, two different benefits

    Where a therapy falls outside the medical benefit, the patient's route to it runs through their drug plan instead -- a different payer, a different authorization, a different appeal chain, and a different conversation about cost.

  • A presumption that fits the specialty badly

    Subcutaneous injection is the route rheumatology's mainstay therapies use, and it is the route the manual presumes is self-administered. The specialty starts most of these questions on the wrong side of the default.

  • A frequency rule that is easy to state wrongly

    Scheduling bone density on a two-year recall looks correct and is not what the regulation says. The count is months since the month of the last measurement, and the number is 23.

Documentation and coding considerations

The notes below describe coverage policy and documentation considerations from the Medicare manuals and regulation; they do not reproduce any code descriptions.

  • How the threshold is defined

    "Usually" means more than 50 percent of the time for all Medicare beneficiaries who use the drug. Above that, the drug is excluded and the contractor may not make any payment for it. The manual notes reliable statistical information is not always available, which is why the route presumptions exist.

  • Per indication, then weighted

    Contractors make a separate determination for each indication, then weigh each indication's contribution to total use of the drug to reach a single overall determination. One drug gets one answer, even where its indications differ.

  • The route presumptions and how they are rebutted

    Intravenous and intramuscular delivery are presumed not usually self-administered; subcutaneous delivery is presumed self-administered. The subcutaneous presumption is examined against whether the condition is acute and how often the injection is given -- monthly suggesting not self-administered, weekly or more often suggesting it is.

  • What "administered" and "by the patient" mean

    "Administered" refers only to the physical process by which the drug enters the body, not to whether a professional supervises it. "By the patient" means beneficiaries as a collective whole, excluding caregivers, ignoring inpatient administration, and excluding beneficiaries who could not self-administer any drug because of an unrelated condition.

  • The bone mass measurement conditions

    Coverage requires an order by the treating practitioner following an evaluation of need including the appropriate procedure, performance under the appropriate level of physician supervision, and a beneficiary in one of the five categories -- including one defined as glucocorticoid therapy equivalent to an average of 5.0 mg of prednisone or greater per day for more than three months. Monitoring response to an approved osteoporosis drug therapy must use axial dual energy x-ray absorptiometry.

Denial and rejection risks

On a biologic, the amount at stake on one line is larger than most encounters, and the reasons for loss are mostly structural.

  • A drug billed under the wrong benefit entirely

    Administering a therapy the contractor treats as usually self-administered means the medical benefit will not pay for it. The product has been used and the claim was never going to succeed.

  • A jurisdiction difference nobody checked

    Contractors each make their own determination. A practice with sites in two jurisdictions, or one that took its policy from a peer elsewhere, can be operating a benefit routing that is correct somewhere else.

  • An injectable form with no case against the oral one

    The route must be medically reasonable and necessary, not just the drug. Where an oral form exists, a record that does not address why the injection was needed leaves the necessity question half answered.

  • Doses given while a patient is trained to inject

    The manual states that Medicare will no longer pay for the limited doses contractors once allowed while a patient was being trained in self-administration technique. That practice is specifically withdrawn.

  • A bone density scan inside the frequency standard

    A measurement performed before at least 23 months have passed since the month of the last one falls outside the standard, and is excluded as not reasonable and necessary unless one of the circumstances permitting greater frequency applies and is documented.

Payer-process considerations

The instruments that decide these questions are contractor-level and revisable, which makes monitoring them part of the operation.

  • The determination is the contractor's to make and to revise

    Each contractor makes its own determination for each drug, publishes it, and entertains requests for a determination or for reconsideration of a pending or published one. It is a live document, not a fixed rule.

  • The evidence the contractor must consider is specified

    Contractors are required to consider peer-reviewed medical literature, standards of medical practice, evidence-based practice guidelines, the FDA-approved label and package inserts, and may consider other evidence submitted by interested individuals or groups. That is the shape a challenge has to take.

  • Bone mass measurement runs on its own frequency machinery

    The exceptions to the 23-month standard are examples rather than a closed list, and include monitoring beneficiaries on long-term glucocorticoid therapy of more than three months and a confirmatory baseline where the first measurement was not performed on axial dual energy x-ray absorptiometry.

  • Commercial plans and Medicare Advantage vary

    The self-administration exclusion described here is Original Medicare's. Commercial payers and Medicare Advantage plans set their own medical-versus-pharmacy benefit splits, may require specific acquisition routes, and may apply step therapy to the same drugs.

Revenue-cycle checkpoints

The first three decide whether a claim can exist, which is why they belong before the appointment rather than after it.

  • Confirm, per drug and in this contractor's jurisdiction, whether the therapy is inside or outside the medical benefit
  • Re-check that position when a determination is revised, a site opens in another jurisdiction, or an indication changes
  • Document why the injectable route was reasonable and necessary where an oral form exists
  • Route excluded therapies to the patient's drug plan deliberately, rather than discovering it on a remittance
  • Keep drug acquisition, administration and the claim reconciled, because the product is bought before it is paid for
  • Record which of the five bone mass measurement categories the beneficiary falls into, in the order and the record
  • Count 23 months from the month of the last bone mass measurement, not two years from its date
  • Document the circumstance -- long-term steroid therapy, or a confirmatory baseline -- when measuring sooner

Related & connected

Services, tools, background reading and definitions that connect to the rheumatology revenue-cycle steps above.

Frequently asked questions

Why is one biologic covered in the office and another not?

Because Medicare covers drugs furnished incident to a physician's service only where they are not usually self-administered by the patients who take them, and the Benefit Policy Manual defines "usually" as more than 50 percent of the time for all Medicare beneficiaries who use the drug. Above that threshold the drug is excluded and the contractor may not make any payment for it. The test is about the drug and about beneficiaries as a population -- so two drugs a rheumatologist regards as interchangeable can land on opposite sides of it, and nothing about an individual patient changes the answer.

How is the determination actually made?

In two steps, and with presumptions where data is thin. Contractors make a separate determination for each indication, then determine each indication's relative contribution to total use of the drug and take a weighted average to produce one overall answer. Where reliable statistical information on self-administration is unavailable, they presume -- absent evidence to the contrary -- that intravenous drugs are not usually self-administered, that intramuscular drugs are not usually self-administered, and that subcutaneous drugs are self-administered. The subcutaneous presumption is examined against whether the condition is acute and how frequently the injection is given.

What counts as an acute condition for this test?

The manual defines it for this purpose as a condition that begins over a short time period, is likely to be of short duration, and where the expected course of treatment is a short, finite interval -- and states that a course of treatment consisting of scheduled injections lasting less than two weeks is considered acute regardless of frequency or route. Evidence supporting the characterization may include Food and Drug Administration approval language, package inserts and drug compendia. The point of the definition is that an acute condition makes self-administration less likely, which is one of the two factors that can rebut the subcutaneous presumption.

Who is included in the population the determination is based on?

Medicare beneficiaries as a collective whole. Only the patients themselves count -- spouses, friends and other caregivers are not the patient for this purpose -- and instances of inpatient administration are ignored. Beneficiaries who do not have the capacity to self-administer any drug because of a condition other than the one being treated are left out of the population; the manual gives paraplegia and advanced dementia as examples, while noting that someone at an early onset of an otherwise debilitating condition would be included. The determination is made drug by drug, not beneficiary by beneficiary.

How often will Medicare cover a bone density measurement?

42 CFR 410.31 sets the standard as at least 23 months since the month the last bone mass measurement was performed -- a count of months, from a month, rather than a two-year anniversary of a date. More frequent measurement may be covered where medically necessary; the regulation gives monitoring beneficiaries on long-term glucocorticoid therapy of more than three months, and allowing a confirmatory baseline where the initial measurement was not performed on an axial dual energy x-ray absorptiometry system, as examples rather than as a closed list. Coverage also requires the beneficiary to fall into one of five named categories, one of which is defined by a dose: glucocorticoid therapy equivalent to an average of 5.0 mg of prednisone or greater per day for more than three months.

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