For hospital-based pharmacists, CMS is deferring to the state scope-of-practice regulations. If a pharmacist is functioning within state scope-of-practice regulations, does not contradict your state emergency or pandemic plans, is providing services incident to a physician/non-physician practitioner (NPP) order, and the service is not one that is covered under Medicare Part D, then the facility may submit services provided by a pharmacist on a UB-04 claim form. These must also meet other requirements, such as medical necessity and documentation.2 Telephone services, such as CPT® codes 98966-98968 or HCPCS codes G2061-G2063, may be reported by auxiliary staff, which includes pharmacists.2
If a pharmacist employed by the hospital provides services to patients in temporarily relocated off-campus provider-based departments (which may include patients’ homes) using telecommunications technology in accordance with the extraordinary circumstances exception outlined in the interim final rule, CMS-5531-IFC, then these services may be submitted on the UB-04 as well. (05/06/2020)
1CMS-5531-IFC, “Medicare and Medicaid Programs, Basic health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program”, page 25 (April 30, 2020)
2Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency, Telehealth Evaluation and Management (E/M) Services, page 2 (March 18, 2020)