Primary Care Coding Alert

Question: When an FP performs a blood draw at a patient's home and then transfers the blood back to the office lab, can we bill for the venipuncture and the specimen transfer, or is the handling included in the blood draw code?

Mississippi Subscriber

Answer: Several issues must be considered when coding this service. First, you have to know the individual payer and its rules regarding billing for services performed out of the office. For example, Medicare has specific rules regarding billing for this scenario. If the FP personally performs the venipuncture, it can be billed using G0001 (Routine venipuncture for collection of specimen[s]). Medicare bundles the specimen handling (99001), so it cannot be separately reported. A home visit code (99341-99350) can be reported only if the physician performed a significant, separately identifiable service.

The physician could not send his nurse to perform the service and then bill it as if the physician had personally performed the service. Under Medicare "incident-to" rules, if auxiliary personnel perform services outside the office setting, as in a patient's home, their services are covered incident-to a physician's service only if there is direct personal supervision by the physician.

For example, if a nurse accompanied the physician on house calls and administered an injection, the nurse's services are covered. If the same nurse made the calls alone and administered the injection, the services are not covered (even when billed by the physician), since the physician is not providing direct personal supervision. (See Medicare Carriers Manual, Part 3, Section 2050.2, Services of Nonphysician Personnel Furnished Incident-to Physician's Services.)

Also for Medicare, if a nonphysician practitioner (e.g., nurse practitioner, physician assistant, or clinical nurse specialist) performs the venipuncture and it does not meet the incident-to requirements, the service must be reported using the non-physician practitioner's provider number. It could not be reported under the physician's provider number.

For other insurers, the venipuncture can be reported using either G0001 or 36415* (Routine venipuncture or finger/heel/ear stick for collection of specimen[s]).

According to CPT Assistant October 1999, the code for handling and/or conveyance of a specimen for transfer is used when the physician incurs some expense, e.g., "work involved in the preparation of a specimen prior to sending it to the laboratory. Typical work involved in this preparation may include centrifuging a specimen, separating serum, labeling tubes, packing the specimens for transport, filling out lab forms, and supplying necessary insurance information and other documentation."

If the physician simply draws the blood, labels the tube(s) with the patient's name and date, and takes the specimen back to the office to perform the test, the handling and/or conveyance of the specimen should not be separately reported.

Keep in mind that the same coding instructions apply for the transportation of a specimen obtained in the physician's office and transported to the laboratory (99000). Further, many payers bundle the handling and/or conveyance of specimen codes just as Medicare does.

For non-Medicare patients, you should check with the insurer to obtain its billing requirements when the physician sends a nurse or nonphysician practitioner to perform a venipuncture in the patient's home.

Answered by Joy Newby, LPN, CPC, president of Joy Newby & Associates Inc., a reimbursement consulting company in Indianapolis.