number of units populating correctly on the
claim for each drug/biological line item?
Are any modifications needed
within the Chargemaster?
Does the line item description identify that
the drug/biological was obtained from
a single-use package? If not, how will an
external reviewer be able to validate that
the billed drug/biological wastage was
obtained from a single-use package? Is
the –JW modifier hard-coded within the
Chargemaster? If so, how is this impacting claims for payers other than traditional
Medicare? If the –JW modifier is not hard-coded within the Chargemaster, who is
responsible for manually applying the –JW
modifier to the discarded drug/biological
line item(s) prior to bill submission? How is
the need for the modifier being communicated if/when appropriate?
Audit and monitor
Does your provider administer separately
payable Part B drugs? If you are not sure,
obtain the most current version of Medicare’s
Hospital OPPS Addendum B. 4 Filter this
database for Status Indicators (SI) G and K.
This is a relatively quick way to identify separately payable, Part B drugs/biologicals that
may require use of the –JW modifier. Review
the Chargemaster(s) for your organization
to determine whether any of the identified, separately payable drugs/biologicals
from Addendum B are built within them.
Request, from your data team, a report
identifying outpatient claims with dates
of service on or after January 1, 2017 that
contain any of the HCPCs codes or asso-
ciated Chargemaster numbers for those
separately payable drugs/biologicals built
into your organization’s Chargemaster(s).
Use this report data to perform an internal
review of cases that may have required use
of modifier –JW. Work with the appropriate staff members to determine whether
the drug/biological used originated from
single-use packaging. If so, determine
whether the most efficient packaging size
available from the manufacturer was used,
whether the medical record documentation supported both the administered and
the wasted doses, and whether the claim
exhibited appropriate use of the – JW
modifier in seeking reimbursement for the
Mandating use of the –JW modifier may be
viewed as an inspiration for organizations
to exhibit enforcement of the auditing and
monitoring element of an effective compliance program. Due to the many operational
challenges providers face to ensure appropriate use of this modifier, you may want to
review the internal processes related to –JW
modifier application. This will help ensure
your organization is receiving proper reimbursement for justified wastage of discarded
The views and opinions expressed in this article are those of
the author and do not necessarily represent the views and
opinions of Mercy Health.
1. AAPC: HCPCS Modifiers. HCPCS LEVEL II: Expert. Salt Lake City,
2016. Inside front cover.
2. Centers for Medicare and Medicaid Services: “Drugs and
Biologicals: Section 40 — Discarded Drugs and Biologicals”
Medicare Claims Processing Manual. 2017. Available at
3. CMS: “JW Modifier: Drug/Biological Amount Discarded/Not
Administered to Any Patient Frequently Asked Questions.” 2016.
Available at go.cms.gov/2B7w24V.
4. CMS: Medicare OPPS Hospital Addendum Part B. Available at