Wiki Lab Only Visits

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I just started coding for a FQHC clinic with Indian Health Services. They have been coding lab only visits using the nurse visit code 99211 along with the venipuncture code and outside lab handling code. Their reason for coding it this way is because Medicare will not pay for the lab services and they want to be reimbursed so they are charging a nurse visit code because the RN is doing the draw and it is done incident to the provider being in house. I do not agree with any of it because the visit does not meet the criteria of the 99211 evaluation and management guidelines. The majority of the labs are sent out but they are not indicated on the claim with modifier 90 so the insurance does not really know from us if we sent the lab out until they get a claim from the outside lab. I believe this is fraud on their part to get the claim paid. Can I get anyone else's thoughts on this or how your facility would code a scenario like this.

Thank you,
Lisa
 
I work for a non-FQHC 638 tribal clinic

You are very right to be concerned. Lab visits should never get an E/M code just to get the labs paid for Medicare. Send-out labs should absolutely have the modifier -90 attached

This sounds very sketchy to me, and I would send your direct supervisor an e-mail stating your objections. That MAY help cover you under respondeat superior
 
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