Hospitals Must Report ICD Code for Outreach Patients

Longstanding Medicare policy recognizes that hospitals act in the capacity of an independent laboratory when they provide clinical laboratory tests to outreach (i.e., nonhospital) patients. Many hospitals today have outreach programs through which blood, urine, and related specimens are transported from physician offices, clinics, and other nonhospital sources for test performance in the hospital laboratory. Hospitals are to bill their Part A MAC for tests payable via the clinical laboratory fee schedule for nonhospital patients using Form CMS-1450 (UB-04) showing type of bill 014x. Until recently, hospitals billing their Medicare Part A contractor for clinical lab tests to nonhospital patients did not have to include an ICD diagnosis code on the claim. The instructions for field FL67 (principal diagnosis code) in §75.5 of the Medicare Claims Processing Manual included an end-note stating that “Diagnosis codes are not required on non-patient [i.e., outreach or nonhospital patients] claims for laboratory services where the hospital functions as an independent laboratory.”  Transmittal 2922 (Change Request 8577) dated Apr. 3 requires hospitals to include an ICD diagnosis code on Form CMS-1450 claims for clinical lab tests for nonhospital patients starting Apr. 18. A principal objective for this transmittal according to CMS is to “delete the note in §75.5 FL67 that indicated that hospitals do not need to report diagnosis codes on non-patient claims for laboratory services where the hospital functions as an independent laboratory.” In accordance with longstanding Medicare policy for independent laboratory billing for clinical tests, the ICD diagnosis code for a nonhospital patient Form CMS-1450 claim filed by a hospital is the sign, symptom, or other clinical information furnished by the referring physician on the requisition.

Source: https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R2922CP.pdf