Author Topic: Medicare and nursing home patients  (Read 848 times)

jennBenn

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Medicare and nursing home patients
« on: July 06, 2021, 03:37:55 PM »
We are a private practice specialist that occasionally sees nursing home and assisted living facility patients. Someone had once told me that we could not draw blood and process their labs in our own lab. I'm trying to verify if this is accurate. Can anyone help me out?

RichardP

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Re: Medicare and nursing home patients
« Reply #1 on: July 07, 2021, 05:40:32 AM »
Jenn - this is probably a question for a health-care attorney who knows the rules for lab billing for your state.

Having said that, I will assume you know the difference between a Physician Office Lab (POL) and a commercial lab.  I will also assume you understand the concept of "billing entity".  If you don't, just say so and someone will explain further.

For the Physician Office Lab, the billing entity is the provider who owns the lab.  All work done by the lab is billed using the CLIA and NPI numbers of the physician who owns it.  Only the patients of the provider who owns the lab may use that lab.  Patients of other providers may not be referred to a POL (although they could be referred to the owner of the POL for an office visit that might result in lab work being done in their POL).

If it is not a POL, then it is considered a commercial lab and must bill using its own CLIA number and NPI number.  Since it is a commercial lab, anyone may use it, and any patient's work may be referred to it.

We bill for several providers who have POLs.  I was involved in researching the regulations when they were set up.  Both the State and CMS regulate POLs.  At the time these labs were set up, the regulations required that the POL be established within X number of feet of the providers actual office, and could only be used by that provider's patients who came to the providers office.  I don't remember if that was a State (California) requirement or a CMS requirement.  But, obviously, if your lab is subject to such a requirement, then bringing in blood from someone seen at a different location would not be permitted.  If you are running a commercial lab that bills using its own CLIA and NPI numbers, then that activity would (probably) be permitted.  Best to check with a health care attorney who knows the lab regulations for your State.

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Re: Medicare and nursing home patients
« Reply #1 on: July 07, 2021, 05:40:32 AM »