Question:
What compliance and billing challenges can arise when multiple hospital departments perform laboratory testing, particularly with point-of-care testing (POCT)? In this regard, do you have any insight into billing modifier 91?
Answer:
For the hospital laboratory, it is of great importance to be aware of other departments that may also be performing laboratory tests and billing with codes that will create an NCCI edit (MUE or PTP) at the time of claims processing. This frequently occurs with point-of-care testing (POCT) performed in a variety of clinical departments, such as respiratory therapy, the emergency department, or intensive care units. Compliance with billing guidelines and the appropriate use of modifier 91 for sequential testing is a significant challenge. Many times the corrective action will be to reverse a lesser component charge in order to bill the comprehensive/more significant charge. This presents the need for each department to understand that testing may not equal billable charges. Note that modifier 91 should not be used when repeat testing is not medically necessary. For instance, when test orders are duplicated simply to trigger a faster result as seen when point of care testing performed in the Emergency Department duplicates components of a comprehensive lab order.
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