# Validity testing separately billable with drug testing codes?



## lch (Mar 19, 2015)

We have a physician owned lab (POL) within our pain clinic in Tennessee. I interpret the new CCI guidelines as of 1/1/15 to say that validity testing is not separately billable (pH, creatinine, etc.) with 83986 and 82570 and that it is included in the drug testing codes. There are differences of opinion on this within our practice. These are being done to support that the urine is indeed urine and not been tampered with. I completely understand the reasoning for doing these validity tests, I just don't think they are separately billable per CCI guidelines. Any thoughts/advice on this would be greatly appreciated! Thanks


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## dwaldman (Mar 22, 2015)

.  Drug Testing  Providers performing validity testing on urine specimens utilized for drug testing should not separately bill the validity testing. For example, if a laboratory performs a urinary pH, specific gravity, creatinine, nitrates, oxidants, or other tests to confirm that a urine specimen is not adulterated, this testing is not separately billed.  The Internet-Only Manual, Publication 100-04, Medicare Claims Processing Manual, Chapter 16 (Laboratory Services), Section 10 (Background) indicates that a laboratory test is a covered benefit only if the test result is utilized for management of the beneficiary?s specific medical problem.  Testing to confirm that a urine specimen is unadulterated is an internal control process that is not separately reportable.  

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 I would write a letter regarding the pending issues, so your practice can get a formal response from NCCI. You can state what the difference of opinion is about the above paragraph.  The true intent of this paragraph can be confirmed.

http://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/index.html


This web page provides information to providers on Medicare's NCCI edits but does not address specific NCCI edits. If the viewer has concerns about specific NCCI edits, he/she may submit comments in writing to:

National Correct Coding Initiative
 Correct Coding Solutions LLC
 P.O. Box 907
 Carmel, IN 46082-0907

Attention:  Niles R. Rosen, M.D., Medical Director and Linda S. Dietz, RHIA, CCS, CCS-P, Coding Specialist

Fax #:  317-571-1745


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## lch (Mar 22, 2015)

Excellent idea. Thank you so much for your help with this.


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## marvelh (Apr 6, 2015)

It's not that Medicare doesn't see the importance of performing validity testing, it's that they don't consider it to be a diagnostic clinical lab test, i.e. the testing is not being performed to diagnose or manage the patient's renal function, etc. instead it is performed to verify that the specimen has not been adulteraed.  

The following is from Palmetto, one of the Medicare contractors:
According to 100-4, ch 16,?10, a diagnostic laboratory test must be ordered by the treating physician and the test results must be used in the management of the beneficiary?s specific medical problem. Although some laboratory requisitions allow the ordering physician to designate specimen validity testing (e.g.: creatinine, oxidant, pH, specific gravity) to ensure that a patient specimen has not been adulterated, the results of this testing are not used in the management of the beneficiary?s medical problem. Therefore, Palmetto GBA has determined that specimen validity testing is a statutorily excluded service. Reference: IOM 100-04, Ch16,?10​


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