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Pathology global billing place of service

Julia Posted Mon 06th of October, 2014 15:56:49 PM

We are a private pathology group performing the professional and technical component of hospital (inpatient, outpatient & ER) specimens. Specimens are collected at the hospital/outpatient facility then transcported to our laboratory for processing and physician diagnosis. Should we be billing POS 81 or 21, 22 or 23? If we bill POS 21, 22, or 23, we are concerned that a 26 modifier will be appended to our claims. Should we be able to collect global reimbursement for both professional and technical with 21, 22 or 23? Are there CMS guidelines that specifically address this matter and support global reimbbursement with these POSs that we can use to support appeals with private payers in case they do append the 26?

SuperCoder Answered Tue 07th of October, 2014 09:48:28 AM

Thank you for your question.
POS 81 would be appropriate for billing/coding. The interpretation and report are being done in the lab setting, not at the inpatient/outpatient facility.

81 Independent Laboratory A laboratory certified to perform diagnostic and/or clinical tests independent of an institution or a physician's office.

Julia Posted Thu 09th of October, 2014 11:57:36 AM

I was reading another question asked 8 months ago by user id 17700 and the answer at that time was that you should use the POS code that describes the patient location when the specimen was taken. These are specimens being taken at the hospital where our doctors are Directors of the Lab and then brought to our facility for processing and interpretation. We are contracted with the hosital to bill global for these services. Which would be correct 81 or 21,22, and 23?

SuperCoder Answered Fri 10th of October, 2014 06:42:27 AM

CMS requires that the POS be the location where the service actually took place. In the new guidelines, the TC and the PC of the diagnostic test may be reported with different POS codes if they took place in different locations. The Medicare Physician Fee Schedule has two payment rates for a number of procedures.

If the physician bills for a lab service furnished by an independent lab, the code for "Independent Laboratory" is used. If an independent lab bills, the place where the sample was taken is shown. An independent laboratory taking a sample in its laboratory shows "81" as place of service.

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