Pathology/Lab Coding Alert

Question: I read in your newsletter Vol. 14 No. 11 “Don’t Confuse Blood Draw with Analysis” that an arterial puncture must be performed by a physician. We have clinical lab scientists who perform this procedure — could you please clarify?

Minnesota Subscriber

Answer: For arterial puncture, the procedure must be performed by a physician (M.D or D.O) for payment by Medicare.

If you have clinical lab scientists who draw arterial samples, you may have difficulty billing for the acquisition of the specimen. Medicare pays for 36600 (Arterial puncture, withdrawal of blood for diagnosis for arterial blood gas analysis) on the physician fee schedule, and you can bill this code to Medicare only if a physician performs the service.

Bottom line: The article you mentioned should have stated that the 36600 service must be performed by a physician if you’re billing Medicare or other payers that follow Medicare rules on this point.