I am having this problem with one of my clinics and I would like other auditors take on how to solve this. We have a phlebotomist at one of our sites that does all of the veinpunctures for labs. According to the site, she is responsible for the lab, but if she is busy the other nurses will chip in and help. The site however is billing the veinpuncture under the phlebotomist. I have concern here that this should not be occuring if she did not perform the veinpuncture. I know that you can't bill for services not performed, but can anyone point to guidelines that state this? I plan to go to the clinic to straighten this out but I need something to back me up here. Any insight? Thanks.