This physician is billing for blood draws in the hospital outpatient setting.
Question: We have a physician who is currently billing for infusion services in a hospital outpatient department. The department is asking for clarification as to whether or not this is appropriate. The services are: 96365-IV Infusion and 99195-Phlebotomy therapeutic.
Answer: According to CPT the 96365 code was not intended for use in the clinic or in the hospital but rather in a free-standing outpatient office. The provider is allowed to bill the 99195 in this setting - but it has no physician work RVU. Is the physician actually drawing the blood? Normally physicians don’t do that themselves. If they do, they should charge for it.
Bill Dacey, CPC, MBA, MHA, is principal in the Dacey Group, a consulting firm dedicated to coding, billing, documentation, and compliance concerns. Dacey is a PMCC-certified instructor and has been active in physician training for more than 20 years. He can be reached at firstname.lastname@example.org or email@example.com.
This question originally appeared in the November 2010 issue of Physicians Practice.