Wiki Coding a Nurse Visit...

[gsccardmore16]

We are a RHC and trying to figure out how to code our lab visits. Let me explain. We have a contract with our local hospital lab co. We draw the labs in our office and their carrier comes and picks them up. I cant charge a Venipuncture code because the lab supplies are provided by the hospital and I cant charge a 99000 because we dont employee the lab carrier company that picks up the specimen. So how do I compensate for the time our nurses use to draw and prepare the labs? Keep in mind we only bill the self pay patients from our office. All insurance labs are drawn in our office and the insurance info is sent with the order and specimen to the hospital and then they bill. Can I charge the insurance some time of fee? Im very confused...

 

[christinaoliver]

I think you would not be able to bill a 99211. If all the nurse is doing is drawing the blood and no evaluation and management service is being provided then a 99211, would not be appropriate to bill the patient , insured or not.

 

[gsccardmore16]

I think you would not be able to bill a 99211. If all the nurse is doing is drawing the blood and no evaluation and management service is being provided then a 99211, would not be appropriate to bill the patient , insured or not.

So really there isnt anything I can code to compensate the nurses time, correct?

 

[thomas7331]

I'm not familiar with the rules specific to a RHC, but I'm not sure I understand your rationale for not billing a venipuncture charge just because the lab supplies are provided by the hospital. The venipuncture code, e.g. 36415, reports the work of the procedure and is not a supply charge. This would be the most appropriate code to represent the nurses' time in this situation.

 

[gsccardmore16]

Venipuncuture 36415

Venipuncture is what we were using and we are being told that we cant use it because the supplies are donated from the lab company and that code is to be used to cover the cost of the supplies. I'm just trying to get some clarification as to weather or not I can use it or not. There is nothing in the guideline regarding who buys the supplies or not

 

[thomas7331]

Venipuncture is what we were using and we are being told that we cant use it because the supplies are donated from the lab company and that code is to be used to cover the cost of the supplies. I'm just trying to get some clarification as to weather or not I can use it or not. There is nothing in the guideline regarding who buys the supplies or not

I think this is something you will need to discuss with the person or persons who gave you this instruction, or else with your clinic's compliance officer or other person familiar with your arrangement with the lab. While supplies are included in the venipuncture reimbursement, they are only part of it - it also includes the staff services. Is the laboratory contract providing the supplies at no cost but not compensating the clinic for the services of the staff? If so, there is no way for a coder to 'split' this service and bill just for the nurses' time and not the supplies - billing 99211 to substitute for this would be inappropriate since this is not the service that was performed. This arrangement also raises some questions in my mind about compliance aspects of this contract because supplies provided at no charge could be considered a kickback or illegal inducement to refer services. In my opinion, this is really something that should be looked at carefully with someone with some compliance background who can both review the contract and also give you the proper instructions as to how you should be handling the coding and billing.

For your reference, here is an article from the OIG regarding their opinion on a situation similar to what you are describing. As you can see, there are some complex legal issues involved in these type of matters, so it would be best to refer the question to someone who has the resources to get you the right answer.

https://oig.hhs.gov/fraud/docs/advisoryopinions/2005/ao0508.pdf