The denial of a venipuncture (36415) or capillary stick (36416) and the bundling of these services with a laboratory procedure or evaluation and management (E/M) service are inappropriate and inconsistent with Current Procedural Terminology (CPT®) guidelines. CPT guidelines clearly state that the collection of a specimen by venipuncture or arterial puncture is not considered an integral part of the laboratory procedure performed (80000 series of codes) and is reported in addition to the laboratory procedure(s) performed. Also, CPT guidelines specify that a procedure with an assigned CPT code may be billed separately from an E/M service.

Although the Centers for Medicare & Medicaid Services (CMS) has never assigned relative value units (RVUs) to code 36415, it does reimburse up to $3 for the venipuncture under the Medicare program. However, there is no such provision for payment of a capillary stick (36416). Many state Medicaid programs and commercial...

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