This does not sound kosher to me either. The CMS1500 has to have the correct Box 24B place of service, (where the test was run- not where the patient was). If it was actually drawn and run in the office, then yes, you can use a POS code 11, but if it was drawn in the office and actually tested at the lab, you have to use the POS code of 81 (independent lab).
The same for Box 32 - it has to show where the test was run, not where the patient is. This address and NPI, etc needs to be tied to the correct CLIA number.
I couldn't say about OK loopholes, but this is what the Medicare guidelines say.
Please reference Medicare Claim Processing Manual 100-04, chapter 16.
Hope this helps.
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