You shouldn’t separately bill venipuncture for hospital inpatients — the service is included in the DRG rate structure.
For hospital outpatients, Medicare generally limits venipuncture (36415, Collection of venous blood by venipuncture) to one unit per patient encounter, even if you draw multiple specimens. A patient encounter means the time from initial treatment/care until discharge from that treatment/care.
The Medicare Claims Processing Manual, Chapter 16, has this to say about routine venipuncture:
“A specimen collection fee is allowed in circumstances such as drawing a blood sample
through venipuncture (i.e., inserting into a vein a needle with syringe or vacutainer to draw the specimen).This fee will not be paid to anyone who has not extracted the specimen. Only one collection fee is allowed for each type of specimen for each patient encounter, regardless of the number of specimens drawn. When a series of specimens is required to complete a single test (e.g., glucose tolerance test), the series is treated as a single encounter.”
You’ll also find that many Medicare Administrative Contractors (MACs) have coverage guidance about venipuncture. For instance, CGS Administrators with jurisdiction in Kentucky provide the following information:
“Submit CPT code 36415 for all routine venipunctures, not requiring the skill of a physician, for specimen collection. This includes all venipunctures performed on superficial peripheral veins of the upper and lower extremities
Multiple venipunctures … during the same encounter, to draw blood specimen(s), may only be billed as a single procedure with units of service = 1 (one) regardless of the number of attempts or veins entered. In an ER setting, an “encounter” is considered admission until discharge. The venipuncture may be billed by the hospital as an outpatient charge. Physicians may not generally bill for routine venipuncture in a hospital site of service.”
36600: Regarding 36600(Arterial puncture, withdrawal of blood for diagnosis), the code is a physician service paid on the Medicare physician fee schedule. The physician may withdraw arterial blood to evaluate blood gases for certain patient conditions.
The service may be bundled, in certain situations, such as critical care. That’s why Correct Coding Initiative (CCI) lists 36600 as a column 2 code with critical care codes such as 99291 (Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes).
Unlike 36415, there’s no national guidance about reporting multiple units of 36600, including no medically unlikely edit (MUE) restriction for the code. However, you should check local payer guidance about reporting multiple physician arterial punctures on the same date.