Know Who Can, and Who Cannot, Bill for Lab Draws
Question: Our clinic laboratory draw station receives laboratory orders from an outside provider. The phlebotomist performs the lab draw, and the lab is sent to be processed at a different location. Who should we report as the billing provider for 36415: the clinic’s on-call provider (“doctor of the day”) or the physician listed on the Clinical Laboratory Improvement Amendments (CLIA) certificate? If neither of those options is appropriate, who would be the correct billing provider to report on the claim? AAPC Forum Participant Answer: In this scenario, the provider billing for 36415 (Collection of venous blood by venipuncture) would be your clinic lab, using your national provider identifier (NPI) and tax ID numbers. However, Box 31 (or the ordering/referring provider field on Centers for Medicare & Medicaid Services [CMS] form 1500) would contain the outside provider’s name and NPI. Without the outside provider’s signed order, you cannot bill for the services. Neither of the other options you mention — the on-call provider or “doctor of the day,” or your lab’s CLIA-certified physician — would be correct. As the on-call provider was not treating the patient, they cannot order labs. And the CLIA-certified physician’s responsibility is to ensure your lab complies with regulations and enforces quality control, as well as providing oversight in your lab. None of these roles gives these providers authority to order or bill for tests. Bruce Pegg, BA, MA, CPC, CFPC, Managing Editor, AAPC
