– 3 vials with each 2.75 cc (10 doses each)
– 1 vial with 5.75 cc (16 doses)

The administration will be weekly over 46 weeks. I read a lot from other coders that they charge by the doses no matter the total cc, in this case 95165 x 46.

Per Medicare guidelines a dose is defined as one (1) cc. Please see below:

Allergen Immunotherapy (Medicare excerpts)
Billing Guidelines:
CPT procedure code 95165 is used to report multiple dose vials of non-venom antigens. Effective January
1, 2001, for CPT code 95165, a dose is now defined as a one- (1) cc aliquot from a single multidose vial.
When billing code 95165, providers should report the number of units representing the number of 1 cc
doses being prepared.

In my case that would mean 95165 x 14 cc total.

Doesn’t this guideline apply to commercial insurances as well? There is a big difference between 14 vs 46 units.