Compliance Corner

A recent Centers for Medicare and Medicaid Services (CMS) program transmittal concerning the jurisdiction for certain laboratory claims created some confusion among laboratory providers. Transmittal R3071CP says it updates Medicare manuals to clarify existing policies but no change in claims processing should result. However, the transmittal does appear to change claims submittals for reference laboratories for specimen collection and travel allowance claims in some cases. The basic “clarification” is that the collection fee or travel allowance is now filed in the jurisdiction where the test is performed, not where the sample is actually collected. According to some laboratories, this represents a change in current billing policy and they will have to change their processes and policies to accommodate this clarification. Further, this clarification directly conflicts with Chapter 16, Section 60.1 of the Claims Processing Manual (Pub. 100-04), which states the following with regard to collection fees: “This fee will not be paid to anyone who has not extracted the specimen.” Providers may experience denials for collection or travel allowance claims and should monitor those claims. If they receive denials, they should identify the reason and remark codes accompanying the denials and contact their Medicare Administrative Contractor to ask about the denials.