Q&A: Applying OIG guidance to laboratory billing policies

Q: What guidelines do the Office of Inspector General (OIG) expect to see in our laboratory billing policies?

A: A hospital should ensure that all claims for clinical and diagnostic laboratory testing services are accurate and that they correctly identify the services ordered by the physician (or other authorized requestor) and performed by the laboratory. The OIG recommends that a hospital’s written policies and procedures state the following:

• The hospital bills for laboratory services only after they are performed
• The hospital bills only for medically necessary services
• The hospital bills only for those tests actually ordered by a physician and provided by the hospital laboratory
• The Current Procedural Terminology or Healthcare Common Procedural Coding System code used by the billing staff accurately describes the service that was ordered
• The coding staff submits only diagnostic information obtained from qualified personnel and contacts the appropriate personnel to obtain diagnostic information in the event that the individual ordering the test fails to provide such information
• The hospital documents receipt of diagnostic information obtained from a physician or the physician’s staff after receiving the specimen and request for services
• Routine audits are conducted to assess the hospital’s regulatory billing compliance

For more information, see The Compliance Officer’s Handbook, Fourth Edition.