Gastroenterology Coding Alert

Question: In the September Gastroenterology Coding Alert article on fecal occult blood testing, Increase Reimbursement by Properly Coding FOBTs, the comment on page 3 about billing for the test on the date the patient is given the sample cards is absolutely incorrect. You cannot bill for a service until it is rendered. Otherwise it is fraud.

Diane Atkinson
Billing office manager
John P. Papp Sr., MD

Answer: The article in question presented the view points of several coding experts. Although one expert expressed the comment noted by the subscriber, two others quoted in that article, Linda Parks and Garnet Dunston, advised gastroenterologists not to bill for fecal occult blood testings (FOBTs) on the day when the sample cards are distributed to the patient because the patient may not return the cards. This could lead the practice to file a false claim for reimbursement.

Pat Stout, CMT, CPC, agrees that gastroenterologists should bill for the test when the sample cards are returned. She refers to Medicares definition of the test, which says [w]hen providers submit a claim for G0107 (screening) or 82270 (diagnostic), they are indicating they have provided the following service, a guaiac-based test for peroxidase activity, in which the beneficiary completes it by taking the samples from two different sites of three consecutive stools. Submitting claims with multiple billing of service is inappropriate.

The Medicare definition, Stout notes, specifically cautions against the submission of multiple claims, which can happen by mistake if the gastroenterologists bills on the day the sample cards are distributed. Medicare also states that the filing of a claim indicates the service has been provided and the test completed, which can only happen after the patient returns the sample cards.