This would not qualify as a diagnostic procedure in the risk section - per the CMS documentation guidelines, they are referring to the risk associated with 'surgical or invasive' procedures that are ordered:
"The risk of significant complications, morbidity, and/or mortality is based on the risks associated with the presenting problem(s), the diagnostic procedure(s), and the possible management options.... If a surgical or invasive diagnostic procedure is ordered, planned, or scheduled at the time of the E/M encounter, the type of procedure e.g., laparoscopy, should be documented.
However, if the provider is obtaining this specimen to be tested, or sent out for testing, it would count for one data point in the MDM.