Medicare Lab Fee Includes Routine Venipuncture
By Ellen Terry


If a patient is a Medicare beneficiary, can you bill Medicare for the routine task of drawing a blood sample? 

The answer: It depends. 

If you perform the lab test in your office, you may not bill separately for the “collection of venous blood by venipuncture,” or CPT code 36415, according to the Medicare Claims Processing Manual.  

However, a significant number of physicians who collect blood and perform lab tests in their office are billing for CPT code 36415 along with the test code, the Center for Medicare & Medicaid Services (CMS) says

“This is not correct billing, as the collection of the specimen is accounted for in the payment for the lab work,” TMA billing and coding specialist Mary Fox said, citing Section 60.1.4 of Chapter 16 of the Medicare manual. 

The manual says the allowed amount for routine specimen collection is included in CMS’ annual laboratory fee schedule. The current allowable amount for routine venipuncture is $3. 

If you are among the physicians who are billing in error, you may receive a personal Comparative Billing Report (CBR) from CMS, which hired analysts to look at Medicare claims dated April 1, 2018, through March 31, 2019. If you had at least 423 visits billed with CPT code 36415 and two other lab codes, you will receive an email notice with instructions for accessing your unique CBR. The CBR will show how your billing practices for CPT code 36415 compare with your peers’ and national averages. It is meant to be an educational tool only. 

Physician-Performed Venipuncture

A properly trained and licensed nonphysician professional is permitted to perform a routine venipuncture for specimen collection. If a venipuncture performed in the office setting requires the skill of a physician for diagnostic or therapeutic purposes, the performing physician can bill Medicare both for the collection – using CPT code 36410 – and for the lab work performed in-office. 

Blood Samples You Send Out

If you draw a blood sample and send it to an outside lab for testing, you can bill and get paid for CPT code 36415. Only one collection fee is allowed for each type of specimen for each patient encounter, regardless of the number of specimens drawn, says Novitas Solutions, the Medicare payer for Texas.

Photo: Creative Commons

Last Updated On

October 16, 2019

Ellen Terry

Project Manager, Client Services

(512) 370-1391

Ellen Terry has been writing, editing, and managing communication projects at TMA since 2000. She hails from Victoria, Texas; has a journalism degree from Texas State University; and loves to read great fiction. Ellen and her husband have two grown sons and a couple of cats.

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