False Claims Act?


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I hope someone can help. If not maybe I can be pointed in the right direction.
I work at an independent lab in North Carolina. The parent company is in Arkansas. (We were recently acquired by this laboratory.) The parent company wants me to bill certain insurances for them under the North Carolina NPI to get payment. The lab I work at in NC is not testing these samples. Is it legal for me to bill these claims? I would love to know where I can find resources to support whatever the answer is, whether yes or no.
Thank you for any help someone can provide.


Pasadena/LaPorte Texas Chapter
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My recommendation is to only submit a claim for a lab test that was both ordered and performed.

Submitting a claim for a test not performed could be a potential false claim.

On the claim form, you should enter (into box 32) the name, address, and zip code of the facility (laboratory). The CMS Medicare Claims Processing document indicates, "If an independent laboratory is billing, enter the place where the test was performed."

Your next step should be to contact your compliance officer and share your concerns.


True Blue
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I agree that contacting your organization's compliance officer would be the correct approach here. There are two types of NPIs, one for organization itself and one for the individual provider performing the services. Depending on which NPI is used and which fields on the claim forms are populated, this may or may not affect payment. In addition, if these are commercial claims, your parent lab may have agreements set up with the payers that allow for billing in the manner in which they've instructed you. All of these factors, and others, may play a role in answering your question and there's no way to say what is right or wrong answer without taking a look everything, so this is a question that really needs to be answered by someone who can get all of the details and do the necessary research.