Author Topic: Urine Drug Screen Billing in the Laboratory Setting  (Read 7383 times)

diagnostico

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Urine Drug Screen Billing in the Laboratory Setting
« on: March 02, 2013, 07:25:24 PM »
Our doctor's offices are using CLIA waived cups with a 12 panel test strip. They are billing 80101QW for the POC testing in their offices.
They then send the samples to our clia waived laboratory. The docs only use Workmen's Compensation and PIP. 

Is it legal for us to do another screening test on each drug class eventhough they have already billed 80101QW?
can we bill 80101 x 12

and

Is it legal for us also to also bill  (doc's only treat WC and PIP patients)
83518 x 4 immunoassay
80299 x 3 (3 positives that need to be confirmed)

I just want make sure that we are doing the right...

Your help is appreciated.

RichardP

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #1 on: March 02, 2013, 11:08:41 PM »
This comment at the end of the linked article might put things in perspective for you:

I know this is a bit of a late reply, but it struck me reading this article that, clinically speaking, the vast majority of POC tools are only useful in ruling out cases, rather than providing a definitive diagnosis. For that, laboratory testing remains essential. An example is spirometry. Office spirometry is helpful, but only in identifying cases that need a full spirometric test and ruling out non-COPD cases, not in diagnosing cases.

From here:  http://www.pharmaphorum.com/2010/05/12/point-of-care-testing-in-clinical-trials/

It is possible your doctors are doing a quick rule out the obvious at the POC, and then are forwarding the sample(s) to the lab for a more thorough diagnostic effort.  Hopefully you can see that those are two distinctly different types of testing on the same sample.

diagnostico

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #2 on: March 03, 2013, 07:47:33 PM »
RichardP,
Thanks for your comment. You have offered great insight.
My only concern is that since the office is currently "screening" the urine, is it legal for the lab to also "screen" the urine using immunoassay? It seems a little redundant and possibly illegal to bill the same procedure twice.

RichardP

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #3 on: March 03, 2013, 11:55:06 PM »
For background, this link defines CLIA-waived tests as simple laboratory examinations and procedures that ... employ methodologies that are so simple and accurate as to render the likelihood of erroneous results negligible; or pose no reasonable risk of harm to the patient if the test is performed incorrectly.

http://www.fda.gov/medicaldevices/deviceregulationandguidance/ivdregulatoryassistance/ucm124202.htm

Then, for specifics, we turn to this link and read on Page 2:

http://www.cms.gov/Regulations-and-Guidance/Legislation/CLIA/downloads/howobtaincertificateofwaiver.pdf

Q:  I am a physician performing urine dip sticks and finger sticks for blood glucose in my office as part of the patient's visit.  Am I considered to have a laboratory and do I need a CLIA certificate?

A:  Yes, the testing you perform qualifies as waived laboratory testing and you need a CLIA Certificate of Waiver. This testing requires a CLIA certificate regardless of how many tests you perform and even if you do not charge the patient or bill Medicare or other insurances.


Per Medicare, there can be a Physician Owned Laboratory (POL), or a clinical laboratory.  One laboratory or the other may bill for a given test, but both cannot bill for the same test at the same time.  If the doctor has a POL, he must have a CLIA number for that laboratory.  The clinical laboratory must have it's own CLIA number.  When the doctor uses his POL, he must bill that lab testing under his own CLIA number for his POL.  Even if the doctor has a POL, he may send the labs out to a clinical laboratory instead of using his POL (note that the doctor must inform his patients that they can use a lab of their own choice; they cannot be compelled to use the doctor's POL).  If the doctor sends the labs to a clinical laboratory, the clinical laboratory must bill for the tests, using their own CLIA number. 

Under the Medicare rules, a doctor may not bill for a lab test(s) using his own CLIA number and then send the same specimen samples to an outside lab - where they run the exact tests the doctor ran, and bill for the testing using their own CLIA number.  Medicare edits will catch that two different CLIA numbers are billing for the same series of tests for the same patient for the same date of service.  However, the doctor can run a series of tests in his POL and then send the specimen samples to an outside lab for a different series of tests.  That situation will pass the Medicare edits because the two different CLIA numbers are billing for two different sets of tests.

Finally, a doctor may send the specimen samples to an outside lab - and the lab runs the tests / creates the slides and sends the results back to the doctor for the doctor to interpret (xray, nuclear testing, pathology - but not urine or blood).  In this instance, the clinical lab will bill the technical component (TC) using their CLIA number, and the doctor will bill the professional component (PC), no CLIA numer required.  (The regulations re. TC and PC are changing as we speak, but that is beyond the scope of your question.)

Those are the definitions and regulations for Medicare.  They apply to all instances where the doctor sees Medicare patients.  But some states (California for example) have their own regulations that impose the Medicare regulations on all Insurance Carriers.  So what you just read would apply to W/C or Blue Cross or HealthNet patients in California, as well as to Medicare patients.

If you are working in California, I can tell you that the Medicare regulations do apply to your doctors and your lab even though your doctors only see W/C and PiP patients.  That is because I know the California regulations .  But I don't know the state law for whatever state you actually work in.  That is why you need to speak with a Health Care Attorney about the laws for your state.  What you described in your original post may be a legitimate issue, or it may be nothing.  Only the appropriate legal counsel can tell you.
« Last Edit: March 03, 2013, 11:59:24 PM by RichardP »

diagnostico

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #4 on: March 04, 2013, 09:22:45 AM »
WOW! RichardP for President.
You are THE MAN. That is great information.
I sincerely thank you...

diagnostico

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #5 on: March 04, 2013, 09:26:25 AM »
In the reimbursement report from the initial message, I have included a reimbursement report from a lab that has billed for the UDS and I know for a fact that the docs office has billed for the same test using an in office CLIA waived test. Ooops somebody is in trouble.

RichardP

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #6 on: March 04, 2013, 11:04:51 AM »
I read your comment that starts with WOW and my first and immediate response was embarrassment.  Thank you for the hyperbole.

Question:  who is it that the doctor and the lab both billed?  The patient?  W/C?  If an insurance carrier was billed, one would think they would note the double billing for the same patient for the same date of service, and reject one or both of the billings.

diagnostico

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #7 on: March 04, 2013, 12:14:10 PM »
RichardP,
My apologies for embarrassing you. I was extremely impressed with your depth of knowledge.

The docs office and the lab are both billing WC and PIP only.

The office is billing 80101QW and the Lab is billing the codes shown in the report from the first post.

RichardP

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #8 on: March 04, 2013, 04:25:10 PM »
My apologies for embarrassing you.  No problem.  I'm just trying to be helpful; I'm not running for President.  Most of our clients have Physician Office Labs and we do a lot of lab billing, but not much CLIA-waived stuff.

If I'm reading your posts correctly, it appears that your lab is billing for codes different from what the doctors are billing.  That should be OK.  If you are both billing for 80101QW for the same patient for the same date of service, I would guess that would be problematic.  But that would be a call for the Insurance Carriers to make.

diagnostico

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #9 on: March 09, 2013, 12:36:59 PM »
RichardP
thanks again for all of your help. Can I ask for your assistance with one more question regarding urine screening billing?
When billing 80101 x 12 at the laboratory i was instructed to bill 83518 x 4. Can you tell me why i should bill 83518 x 4?
thanks

RichardP

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #10 on: March 09, 2013, 04:30:25 PM »
RichardP ... Can you tell me why i should bill 83518 x 4?

Short answer: no.  This is a coding question that requires access to the patient's chart, which I don't have.

Slightly longer answer:  80101 and 83518 are two separate tests.  If the doctor tested 80101 in his office, and you are at the lab, you should be doing a test other than 80101.

To recap a clia-waived situation:

1.  A doctor can take a sample in his office, test part of the sample, and send the rest of the sample off to an outside lab for further testing.

2.  The doctor and the outside lab can both bill for the test(s) they perform, so long as the test(s) the lab performs are different from those the doctor performed.

Your situation seems to satisfy this criterion.

diagnostico

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #11 on: March 09, 2013, 05:14:02 PM »
RichardP,
I can always count on you ....thanks

RichardP

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Re: Urine Drug Screen Billing in the Laboratory Setting
« Reply #12 on: March 10, 2013, 06:23:08 PM »
You are welcome.

For others, see this link to complete the discussion started in this thread.

http://www.medicalbillinglive.com/members/index.php?topic=7196.msg21991#msg21991