Wiki Phlebotomy charge

[okandy]

I work for a multi-practice group. Our clinics contract to send labs to a certain reference lab but the clinic actually bills for the laboratory tests. The reference lab bills the practice. To accomodate the clinic, the reference lab supplies one of their own employees to draw the lab in the clinic. Can the clinic (physician) bill the phlebotomy charge (36415) if the phlebotomist is not an employee of the practice?