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Charge for venipuncture separately

APCs Weekly Monitor, September 17, 2004

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QUESTION: There is a disagreement at our hospital over whether the venipuncture charge for ED patients should be billed separately or included in the E/M acuity level. The service is sometimes provided by the laboratory personnel and sometimes by the ED nurses.

ANSWER: CMS provides a HCPCS code for collection of a specimen via venipuncture (G0001: routine venipuncture for collection of specimens). The coding guidelines for this HCPCS do not specify that this service must be provided by a certain type of healthcare professional. Whether your nursing staff, laboratory staff, or even another healthcare professional draws the specimen, this HCPCS and correlating charge is applicable.

When establishing E/M levels for the ED, hospitals identified those services that nursing professionals provide but can't be billed separately. In this instance there is clearly a mechanism for charging this separately; therefore, it should not be included in the E/M level.

There are several reimbursement issues you should keep in mind when managing under this charge structure. If the ED personnel are the ones that draw the specimen, you may want to establish a separate ED venipuncture charge along with a general ledger number which indicates the ED. This will ensure an accurate correlation of charges with the appropriate cost center.

Another key reimbursement issue which sometimes can cause a problem is that FIs only reimburse for one G0001 charge per encounter. Providers sometimes think this means that they should only charge one unit per day, when in fact this can cause real problems with the cost accounting process. Providers can charge for more than one venipuncture per day, but the charges should reflect the services provided. Adjustments made on the back end can be posted to a tracking account, thus maintaining the integrity of the claim.

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