drug overflow billing

Thoughts, please, on billing for drug overflow for vials. For example:
5FU 50 mg/ml 10 ml vial (500 mg vial) non-savable single dose vial.

Patient is prescribed 520 mg of a drug. Nurse pulls medication from 500 mg/10ml vial but actually pulls 10.4 ml due to drug overflow. She calculates the 0.4 ml as the equivalent of 20 mg of 5FU based on the strength per ml listed on the vial.

Billing options:
1.Since the drug overflow of 20 mg is free product, only 500 mg x 1 is billed.

2.If there is no drug overflow, 10 ml of a new vial for the additional ordered 20 mg must be drawn and 480 mg would be wasted so 500 mg x 2 is billed.

3. Since 520 mg is ordered, should the extra 20 mg be billed as in #2 even though an extra vial has not been opened? How should the extra 20 mg of free product be accounted for, since the drug overflow is provided at no extra cost to the practice and how should it be documented appropriately?

Thank you for your help!

waste

Based on information, if I understand correctly, 500 x 2 must be billed if they are truly single-dose vials (each). CMS has stated that it would like providers to try to limit drug waste, but if it cannot be avoided, then they will pay for that waste. So, it looks, from what I can tell are the facts below, that #2 is the correct option. What do you mean by "free product"?

drug overflow billing

Thank you for your response to my question. The extra drug (overflow) that is contained in the first vial is "free product", since only that first vial, although marked as containing 500 mg, actually contains the ordered amount of 520 mgs, which makes opening the second vial unnecessary. Or should any of the drug overflow from the first vial after the listed vial amount (in this case 500 mgs) be wasted and be taken from a second vial, with 480 mgs from the second vial now wasted. The first vial with the 520 mgs has only been paid as containing 500 mgs, since that is what is listed on the vial but 520 mgs was actually ordered to be administered. Thank you!

Waste- Not

Now "The rest of the story"...... in cases where two vials must be opened to comply with the provider's orders, then two vials - no matter how much waste - are billed (also meticulously documented in the chart [x-amount administered; y-amount waste]. If the free vial noted below fulfills the provider's orders and the 2nd vial is never broached, then only one is reported and the 2nd is returned to pharmacy, full. Hope I understood the facts.

drug overflow billing

Yes, thank you, your answer definitely makes sense. The billing department was concerned that the ordered amount and the billed amounts were different, even though the administered amount was the ordered amount, so they were hoping that we would have to waste the extra "free" amount in the first vial and open the second vial and also waste the rest in the second vial. Thank you for your expertise!