ED Coding and Reimbursement Alert

Question: I know that age is one of the factors that differentiates between the venipuncture codes, but what else is the difference between 36400-36410, 36420-36425, and 36415? And how do these procedures differ from 99195?

Codify Subscriber

Answer: Perhaps the first, and most important, difference between the codes lies in the qualifications of the provider that can administer them. Per CPT^® guidelines, the first four codes you list can only be administered by a “physician or other qualified health care professional,” which CPT^® defines as:

“An individual who is qualified by education, training, licensure/regulation (when applicable), and facility privileging (when applicable) who performs a professional service within his/her scope of practice and independently reports that professional service. These professionals are distinct from ‘clinical staff.’ A clinical staff member is a person who works under the supervision of a physician or other qualified health care professional and who is allowed by law, regulation and facility policy to perform or assist in the performance of a specified professional service, but who does not individually report that professional service.”

So, because services such as 36400 (Venipuncture, younger than age 3 years, necessitating the skill of a physician or other qualified health care professional, not to be used for routine venipuncture; femoral or jugular vein) and 36410 (Venipuncture, age 3 years or older …) are more medically complex than the routine venipuncture service described by 36415 (Collection of venous blood by venipuncture), the procedures must be performed by a physician or qualified professional.

Anatomical location is another difference among codes 36400-36410. As the first three codes are for children under the age of three, and as veins in children that young are often difficult to locate, each code specifies the location of the vein, with 36400 being used specifically for a blood draw from the femoral or jugular vein, 36405 from the scalp vein, and 36406 from veins other than the ones listed. CPT^® code 36410, however, lists no specific veins as it is generally easier to find a large vein on which to perform the procedure in a patient three years or older.

CPT^® codes 36420 (Venipuncture, cutdown; younger than age 1 year) and its corresponding age-related code 36425 (…age 1 or over), on the other hand, reflect another procedure that is also more complex than 36415. In this service, the provider has to access a vein to take a blood sample or inject medication into the patient by incising the skin rather than simply puncturing it. However, even though the complexity for this procedure is greater than the other venipuncture services (as indicated by a work relative value unit [RVU] of 1.01 for 36420 compared to a work RVU of 0.38 for 36400), a physician or other qualified health care professional does not have to perform it based on the CPT^® descriptor.

Finally, though you may hear medical staff, and even professionals, refer to a blood draw as phlebotomy, there is a big difference in its purpose as compared to venipuncture. CPT^® code 99195 (Phlebotomy, therapeutic [separate procedure]) also involves drawing blood, but this time the purpose is not to get a sample but to reduce the patient’s hematocrit, or red blood cell, volume to treat certain diseases of the blood such as D45 (Polycythemia vera). You can remember that difference by paying attention to the word “therapeutic” in the CPT^® descriptor for the code.