Local Coverage Article Billing and Coding

Billing and Coding: Venipuncture Necessitating Physician’s Skill for Specimen Collection – Supplemental Instructions Article

A52470

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Article ID
A52470
Article Title
Billing and Coding: Venipuncture Necessitating Physician’s Skill for Specimen Collection – Supplemental Instructions Article
Article Type
Billing and Coding
Original Effective Date
10/01/2015
Revision Effective Date
08/04/2022
Revision Ending Date
N/A
Retirement Date
N/A
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CMS National Coverage Policy

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Article Guidance

Article Text

The information in this Supplemental Instructions Article (SIA) contains coding or other guidelines for Venipuncture Necessitating Physician’s Skill for Specimen Collection.

Coding Guidelines:

General Guidelines for claims submitted to Part A or Part B MAC:

Procedure codes may be subject to National Correct Coding Initiative (NCCI) edits or OPPS packaging edits. Refer to NCCI and OPPS requirements prior to billing Medicare.

For services requiring a referring/ordering physician, the name and NPI of the referring/ordering physician must be reported on the claim.

A claim submitted without a valid ICD-10-CM diagnosis code will be returned to the provider as an incomplete claim under Section 1833(e) of the Social Security Act.

The diagnosis code(s) must best describe the patient's condition for which the service was performed.

Advance Beneficiary Notice of Noncoverage (ABN) Modifier Guidelines
An ABN may be used for services which are likely to be non-covered, whether for medical necessity or for other reasons. Refer to CMS Publication 100-04, Medicare Claims Processing Manual, Chapter 30, for complete instructions.

Effective from April 1, 2010, non-covered services should be billed with modifier –GA, -GX, -GY, or –GZ, as appropriate.

The –GA modifier (“Waiver of Liability Statement Issued as Required by Payer Policy”) should be used when physicians, practitioners, or suppliers want to indicate that they anticipate that Medicare will deny a specific service as not reasonable and necessary and they do have an ABN signed by the beneficiary on file. Modifier GA applies only when services will be denied under reasonable and necessary provisions, sections 1862(a)(1), 1862(a)(9) , 1879(e), or 1879(g) of the Social Security Act. Effective April 1, 2010, Part A MAC systems will automatically deny services billed with modifier GA. An ABN, Form CMS-R-131, should be signed by the beneficiary to indicate that ‎he/she accepts responsibility for payment.‎ The -GA modifier may also be used on assigned claims when a patient refuses to sign the ABN and the latter is properly witnessed. For claims submitted to the Part A MAC, occurrence code 32 and the date of the ABN is required.

Modifier GX (“Notice of Liability Issued, Voluntary Under Payer Policy”) should be used when the beneficiary has signed an ABN, and a denial is anticipated based on provisions other than medical necessity, such as statutory exclusions of coverage or technical issues. An ABN is not required for these denials, but if non-covered services are reported with modifier GX, Part A MAC systems will automatically deny the services.

The –GZ modifier should be used when physicians, practitioners, or suppliers want to indicate that they expect that Medicare will deny an item or service as not reasonable and necessary and they have not had an ABN signed by the beneficiary.

‎If the service is statutorily non-covered, or without a benefit category, submit the ‎appropriate CPT/HCPCS code with the -GY modifier. An ABN is not required for these denials, and the limitation of liability does not apply for beneficiaries. Services with modifier GY will automatically deny.

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.

Submit CPT code 36410 only for venipunctures necessitating physician skill when performed by a physician on veins of the neck, (e.g., external or internal jugular), or from deep (central) veins of the thorax (e.g., subclavian) or groin (e.g., femoral); and for venipuncture of superficial extremity veins when the skill of a qualified individual properly trained in venipuncture techniques (e.g., nurse, phlebotomist, medical technician) has been clearly demonstrated, according to the terms of this policy, to be insufficient ICD-10-CM I87.8, I99.8 or R68.89 must be submitted on all claims for CPT 36410.

Multiple venipunctures (36410 or 36415) 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.

For claims submitted to the Part B MAC:

All services/procedures performed on the same day for the same beneficiary by the physician/provider should be billed on the same claim.

Claims for Venipuncture Necessitating Physician's Skill for Specimen Collection services are payable under Medicare Part B in the following places of service:

Office (11), Home (12), Assisted living facility (13), Mobile unit (15), Urgent care facility (20), Inpatient hospital (21), Outpatient hospital (22), Emergency room (23), Skilled nursing facility (31), Nursing facility (32), Clinic (49).

For claims submitted to the Part A MAC:

Hospital Inpatient Claims:

  • The hospital should report the patient's principal diagnosis in Form Locator (FL) 67 of the UB-04. The principal diagnosis is the condition established after study to be chiefly responsible for this admission.

  • The hospital enters ICD-10-CM codes for up to eight additional conditions in FLs 67A-67Q if they co-existed at the time of admission or developed subsequently, and which had an effect upon the treatment or the length of stay. It may not duplicate the principal diagnosis listed in FL 67.


  • For inpatient hospital claims, the admitting diagnosis is required and should be recorded in FL 69. (See CMS Publication 100-04, Medicare Claims Processing Manual, Chapter 25, Section 75 for additional instructions.)

Hospital Outpatient Claims:

  • The hospital should report the full ICD-10-CM code for the diagnosis shown to be chiefly responsible for the outpatient services in FL 67. If no definitive diagnosis is made during the outpatient evaluation, the patient's symptom is reported. If the patient arrives without a referring diagnosis, symptom or complaint, the provider should report an ICD-10-CM code for Persons Without Reported Diagnosis Encountered During Examination and Investigation of Individuals and Populations (Z00.00-Z13.9).

  • The hospital enters the full ICD-10-CM codes in FLs 67A-67Q for up to eight other diagnoses that co-existed in addition to the diagnosis reported in FL 67.

Coding Information

CPT/HCPCS Codes

Group 1

(2 Codes)
Group 1 Paragraph

N/A

Group 1 Codes
CodeDescription
36410 VENIPUNCTURE, AGE 3 YEARS OR OLDER, NECESSITATING THE SKILL OF A PHYSICIAN OR OTHER QUALIFIED HEALTH CARE PROFESSIONAL (SEPARATE PROCEDURE), FOR DIAGNOSTIC OR THERAPEUTIC PURPOSES (NOT TO BE USED FOR ROUTINE VENIPUNCTURE)
36415 COLLECTION OF VENOUS BLOOD BY VENIPUNCTURE

CPT/HCPCS Modifiers

N/A

ICD-10-CM Codes that Support Medical Necessity

N/A

ICD-10-CM Codes that DO NOT Support Medical Necessity

N/A

ICD-10-PCS Codes

N/A

Additional ICD-10 Information

N/A

Bill Type Codes

Contractors may specify Bill Types to help providers identify those Bill Types typically used to report this service. Absence of a Bill Type does not guarantee that the article does not apply to that Bill Type. Complete absence of all Bill Types indicates that coverage is not influenced by Bill Type and the article should be assumed to apply equally to all claims.

CodeDescription
011x Hospital Inpatient (Including Medicare Part A)
012x Hospital Inpatient (Medicare Part B only)
013x Hospital Outpatient
079x Clinic - Other
085x Critical Access Hospital

Revenue Codes

Contractors may specify Revenue Codes to help providers identify those Revenue Codes typically used to report this service. In most instances Revenue Codes are purely advisory. Unless specified in the article, services reported under other Revenue Codes are equally subject to this coverage determination. Complete absence of all Revenue Codes indicates that coverage is not influenced by Revenue Code and the article should be assumed to apply equally to all Revenue Codes.

Revenue codes only apply to providers who bill these services to the Part A MAC. Revenue codes do not apply to physicians, other professionals and suppliers who bill these services to the Part A MAC.

Please note that not all revenue codes apply to every type of bill code. Providers are encouraged to refer to the FISS revenue code file for allowable bill types. Similarly, not all revenue codes apply to each CPT/HCPCS code. Providers are encouraged to refer to the FISS HCPCS file for allowable revenue codes.

All revenue codes billed on the inpatient claim for the dates of service in question may be subject to review.


CodeDescription
0300 Laboratory - General Classification
0309 Laboratory - Other Laboratory
0360 Operating Room Services - General Classification
0361 Operating Room Services - Minor Surgery
0369 Operating Room Services - Other OR Services
0450 Emergency Room - General Classification
0456 Emergency Room - Urgent Care
0510 Clinic - General Classification
0516 Clinic - Urgent Care Clinic
0517 Clinic - Family Practice Clinic
0519 Clinic - Other Clinic
0520 Freestanding Clinic - General Classification
0710 Recovery Room - General Classification
0761 Specialty Services - Treatment Room
0920 Other Diagnostic Services - General Classification
0940 Other Therapeutic Services - General Classification
0960 Professional Fees - General Classification
0969 Professional Fees - Other Professional Fee
0975 Professional Fees - Operating Room
0981 Professional Fees - Emergency Room Services
0982 Professional Fees - Outpatient Services
0983 Professional Fees - Clinic

Other Coding Information

N/A

Revision History Information

Revision History DateRevision History NumberRevision History Explanation
08/04/2022 R9

Revision Effective: 08/04/2022
Revision explanation: Annual review, no changes were made.

06/30/2022 R8

Revision Effective: N06/30/2022

Revision Explanation: Annual review, no changes made.

06/17/2021 R7

Revision Effective: 06/17/2021
Revision explanation: Annual review no changes were made.

01/01/2020 R6

Revision Effective: N/A
Revision explanation: Annual review no changes made.

01/01/2020 R5

Revision Effective: 01/01/2020
Revision explanation: Converted to new billing and coding article format.

10/01/2015 R4

Revision Effective: N/A
Revision explanation: Annual review no changes made.

10/01/2015 R3

Revision Effective: N/A
Revision explanation: Annual review no changes made.

10/01/2015 R2 Revision Effective: N/A
Revision explanation: Annual review no changes made.
05/17/2015 R1 Revision Effective date: N/A
Revision Explanation: Accepted revenue code description changes.

Associated Documents

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CMS Manual Explanations URLs
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