Pathology/Lab Coding Alert

Question: If we have a chart for a hospital outpatient that shows multiple blood draws for different lab tests, can we bill multiple units of 36415? Is the answer different for hospital inpatients?

Kentucky Subscriber

Answer: You shouldn’t separately bill venipuncture for hospital inpatients — the service is included in the DRG rate structure.

For hospital outpatients, Medicare generally limits venipuncture (36415, Collection of venous blood by venipuncture) to one unit per patient encounter, even if you draw multiple specimens. A patient encounter means the time from initial treatment/care until discharge from that treatment/care.

The Medicare Claims Processing Manual, Chapter 16, has this to say about routine venipuncture:

“A specimen collection fee is allowed in circumstances such as drawing a blood sample through venipuncture (i.e., inserting into a vein a needle with syringe or vacutainer to draw the specimen).This fee will not be paid to anyone who has not extracted the specimen. Only one collection fee is allowed for each type of specimen for each patient encounter, regardless of the number of specimens drawn. When a series of specimens is required to complete a single test (e.g., glucose tolerance test), the series is treated as a single encounter.”

You’ll also find that many Medicare Administrative Contractors (MACs) have coverage guidance about venipuncture. For instance, CGS Administrators with jurisdiction in Kentucky provide the following information:

“Submit CPT® code 36415 for all routine venipunctures, not requiring the skill of a physician, for specimen collection. This includes all venipunctures performed on superficial peripheral veins of the upper and lower extremities

Multiple venipunctures … during the same encounter, to draw blood specimen(s), may only be billed as a single procedure with units of service = 1 (one) regardless of the number of attempts or veins entered. In an ER setting, an “encounter” is considered admission until discharge. The venipuncture may be billed by the hospital as an outpatient charge. Physicians may not generally bill for routine venipuncture in a hospital site of service.”