The clinical laboratory as a billing provider of diagnostic services is caught in the middle between two entities - the ordering physician / practitioner and the payer – when attempting to maintain compliant documentation for billed services. By referencing the Part B CERT Reminder issued by WPS on January 25, 2010, it is clear that not all payers truly understand the distinction between a requisition submitted to the laboratory and the physician order.   

“Billing for services while operating in an environment of audit” has become my favorite catch phrase for 2010. It has been just over 7 years since the AMA updated the CPT descriptions for hematology procedures adapting the codes to current reporting practice of the clinical laboratory. Still in 2010, one of the most frequently billed outpatient tests continues to be incorrectly or inappropriately reported for reimbursement.