Clarification Regarding the Coding of IV Medications and Chemotherapy on the MDS

We’ve received clarification from the Centers for Medicare and Medicaid Services (CMS) regarding the coding of IV medications and Chemotherapy on the Minimum Data Set (MDS).

CMS staff has provided the following clarification regarding the coding of IV medications administered during electroconvulsive therapy (ECT) treatments on the MDS. ECT is a procedure performed outside of the nursing facility, and similar to dialysis and chemotherapy, the IV medications must be administered to perform the procedure. Therefore, IV medications administered during ECT treatments must not be coded on the MDS in item O0100H.

CMS staff has further indicated that the use of hormonal therapy to treat cancer must not be coded on the MDS in item O0100A, chemotherapy. CMS has stated that these drugs are not chemotherapeutic (antineoplastic) agents and should not be coded as such. Tamoxifen and drugs like it, block estrogen from attaching to estrogen receptors so cells (like some cancer cells that thrive on estrogen) do not get “fed,” resulting in a slow down or halt in growth of cancer cells. It is the policy of CMS that the pharmacologic classification and category of the drug is what drives coding of medication on the MDS. Since Tamoxifen, and drugs like it, are not antineoplastic agents, they should not be coded as such on the MDS.

Case Mix Review staff will immediately implement these clarifications in the audit and reconsideration processes.

Please direct questions related to this clarification to:

Nadine Olness, Minnesota RAI Coordinator
651-201-4313
health.mds@state.mn.us