Primary Care Coding Alert

Question: Why has Medicare been denying venipunctures that I bill with 36415? I stopped using G0001 because HCPCS 2005 crossed out the code.


Minnesota Subscriber


Answer: You're right that you should no longer use G0001 (Routine venipuncture for collection of specimen[s]). However, CPT's replacement code 36415 (Collection of venous blood by venipuncture) is a valid code.

Problem: The National Physician Fee Schedule 2005 originally released 36415 as a non-reimbursable code. Medicare carried over 36415's previous "I" status. The designation means that 36415 is "not valid for Medicare purposes." "Medicare uses another code for reporting of, and payment for, these services," states CMS in the fee schedule document RVUPUFO5.pdf. The I status was appropriate when G0001 was active.

Medicare has since activated 36415, effective Jan. 1, 2005. CMS changed 36415's indicator to "C" (Carriers price the code). "Carriers will establish RVUs and payment amounts for these services, generally on an individual case basis following review of documentation such as an operative report," according to Medicare's file RVUPUFO5.pdf.

Before Medicare issued the correction, many carriers had system edits in place that incorrectly denied 36415 for 2005 dates of service.

Solution: Refile your denied claims(s) electronically, states Cigna Part B Medicare carrier for Idaho, North Carolina and Tennessee. If your payer has not updated their system, send them a copy of Medicare's correction as shown on page 4 of transmittal 363 available from www.cms.hhs.gov/manuals/pm_trans/r363cp.pdf.

Payment: Medicare will reimburse 36415 at $3 per service. Because CMS will pay 36415 on the clinical lab fee schedule, the Part B deductible and coinsurance do not apply.

Editor's note: To view CMS' fee schedule explanation document "RVUPUFO5.pdf," go to www.cms.hhs.gov/regulations/pfs/2005/1429fc.asp. Status code information appears on pages 15 to 17 in Attachment A.

Answers to You Be the Coder and Reader Questions reviewed by Daniel S. Fick, MD, director of risk management and compliance for the College of Medicine faculty practice at the University of Iowa in Iowa City; and Kent J. Moore, manager of Health Care Financing and Delivery Systems for the American Academy of Family Physicians in Leawood, Kan.