JZ Modifier Required July 1, 2023
The much-anticipated mandatory reporting of the JZ modifier for Part B Medicare begins July 1, 2023. The new Medicare policy can be found here. The JZ modifier denotes that no medication waste occurred with a single-use or single-dose medication. CMS instituted this policy to improve tracking and to obtain more rebates from pharmaceutical companies for wasted drugs as required by the Infrastructure Investment and Jobs Act, §90004, implemented in November 2021.
The JW modifier was implemented in 2017 to encourage efficient use of a vial of medication for more than one patient. The JW modifier identified at least 1 unit of wasted drug that was not administered to a patient. In ophthalmology, this applied to large vials of onabotulinumtoxinA (Botox®) that might reasonably be shared between several patients treated on the same day. These two modifiers, JZ and JW, are complementary to one another in the sense that they have opposite meanings.
Announcement of the JZ modifier occurred at the end of 2022 in the CMS Final Rule. Because the new policy is not intuitive or obvious, it raises many questions. CMS published frequently asked questions here. The policy has the potential to cause many denied claims where modifiers are required but not submitted. Simultaneously, this policy engenders closer attention to chart documentation of injected medications administered and discarded.
Corcoran Consulting Group is preparing additional information on this important topic prior to July 1, 2023. Watch for an announcement in this forum.
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