Wiki Non Office Blood Draws by MAs

aknoper

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Hello!
I work with a group of FNPs who provide Palliative and Primary Care services for patients that reside in ALFs. One of their MAs is a certified phlebotomist who will go out and perform blood draws for patient's with orders and send them off to labs. She is performing these blood draws without supervision as the FNPs are not in the ALFs at the time this is done. Can I still bill 36415 for these draws even though the FNP is not there with the FNP listed as the rendering provider on the claim? They want to be reimbursed for their time but I am not sure how to go about billing for this since they are not a lab and incident to provisions are not being met.
Also came across P9603 and P9604 in my research. Are those codes only for labs or would they also apply to this scenario where the Certified Phlebotomist is traveling for the blood draws and then we just bill the whole thing under the FNP?
Thanks in advance for your help!
 
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