Are there any legal restrictions to claiming more than one blood transfusion on the same day for the same patient?

Context

There is nothing in the MBS to preclude multiple transfusions (item 13706) being provided on the same calendar day and the item number covers three different types of regularly provided transfusions (blood, platelets, IVIg). There are ample examples in ICU when a patient legitimately requires multiple appropriate transfusion episodes during a 24 hour period and these are due to changing clinical circumstances, not part of a pre-defined transfusion plan (e.g. blood transfusion at 4am with 2 units of packed cells, subsequent transfusion of platelets and another unit of blood at 2 pm and another transfusion with a unit of blood at 10pm – for ongoing surgical bleeding). In my interpretation these would account for three distinct, time separated transfusion episodes and item 13706 should be claimed three times. However, Medicare seems to reject claims with more than two 13706 items on it. The error message is usually that the service has already been paid or maximum number reached. This is in spite of times and NDS override documented on the submission. Also, how does one reconcile a massive transfusion episode in billing (sometimes dozens of units of blood and platelets are given) – clearly this is a very different level of clinical workload and involvement compared to a single unit transfusion.

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