Oncology & Hematology Coding Alert

A patient has blood drawn at an oncology-hematology practice for routine diagnostic or chemotherapeutic follow-up tests. While this can generally be referred to as a phlebotomy, it should not be coded as 99195 (phlebotomy, therapeutic [separate procedure]). Knowing this can save oncology practices the time and hassle of having to resubmit a denied claim.

While 99195 is for a procedure that requires blood to be drawn, a therapeutic phlebotomy is designed to address specific blood-related maladies, such as polycythemia vera, 238.4, a hematopoietic stem cell disorder characterized by sustained abnormal elevation in the number of red blood cells. Therapeutic phlebotomy is most often associated with the hematology side of oncology practices, but can easily be confused with blood draws that are common in follow-up care for chemotherapy. It is easy to misunderstand the word phlebotomy and apply it to include all blood draws, says Margaret Hickey, MS, MSN, RN, OCN, CORLN, an independent coding consultant based in New Orleans.

Coding for Routine Blood Draws

Rather than coding routine blood draws as 99195, practices should use either 36415 (routine venipuncture or finger/heel/ear stick for collection of specimen[s]) bundled within an evaluation and management (E/M) code, 99211-99215, or a laboratory test code, such as 85022 (hemogram, automated, and manual differential WBC count [CBC]). This will ensure their coding practice for blood draws complies with Medicare regulations.

Coders should determine the nature of the phlebotomy before assigning a procedure code, says Alice G. Ettinger, RN, MSN, CPNP, program coordinator for the division of pediatric hematology and oncology at St. Peters University Hospital in New Brunswick, N.J.

How a practice codes for routine blood draws depends largely on whether it has its own laboratory, sends the specimen to an outside source, or if patients are sent to another place. Below are common coding scenarios:

Outside lab for both blood draw and testing. If the practice sends its patients outside for drawing blood and testing, it cannot bill for either procedure. If a physician did not extract the specimen from the patient, payment will not be allowed. However, if the test was ordered during a visit related to chemotherapy treatment, the practice may be able to code the appropriate E/M service that describes the follow-up visit.

Collect specimen for testing at outside lab. Although testing is done by an outside laboratory, practices can still bill for the blood draw, says Ettinger. Local medical review policies also say that separate charges made by physicians, independent, or hospital laboratories for drawing or collecting specimens should be allowed whether or not the specimens are referred to doctors or other laboratories.

Most Medicare carriers allow for one collection fee for each patient encounter, regardless of [...]