Re: Multiple CPT Code Billing

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From:Don Hammer <>
To:"Jennings-Siena, Debbie" <>
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Hi Debbie,

I agree with you on your interpretation and have stated my understanding
here earlier altho I didn't see it posted.  I have to say tho, that the
Compliance Officer for the hospital will not be ultimately responsible, the
lab manager and/or Histology supervisor will more than likely be the person
challenged.  The writing of billing procedures and the training of all staff
is the responsibility of the person in charge of the lab.

Now,  an earlier post I sent about ONLY the Pathologist/ Director being
recognized  under CLIA Regs. will probably cause him/her to be ultimately
responsible.  I also stated, the techs and lab managers/administrators
usually take on the responsibility AND  in most cases the Lab Director
hasn't a clue to billing situations/problems/regulations/etc./etc. (nor do
they usually have the time)

Does she/he write the billing procedures and teach them?  I bet not in very
many cases.  When the audit is performed, who will answer the questions?

It's similar to CAP inspections, isn't it?  Who puts together the response
to deficiencies and who signs the report returned to CAP?  The lab
manager/administrator usually write the report and the Pathologist/Director

CLIA recognizes just the Pathologist/Director as the responsible person for
ALL aspects of the Anatomic Laboratories because that is the way the I think
the Pathologist's wanted it to be set why is everyone working so
hard at a salary that does not attract new comers into the profession to
make she/he shine? :)  (see messages posted on recruitment to the

Don Hammer, Retired Guy
----- Original Message -----
From: Jennings-Siena, Debbie <>
To: 'Robert Santoianni' <>
Cc: <>
Sent: Wednesday, February 23, 2000 1:38 PM
Subject: RE: Multiple CPT Code Billing

> Robert,
> It is my opinion that according to everything that I have read about CPT
> coding that you are only allowed to charge for each different special
> on multiple blocks from the  same case.  For example, if you are doing an
> AFB and a GMS on Blocks A1 and A2 (same specimen) that is permissible as
> long as each special stain is mentioned in the final report.  IF you are
> doing an AFB on blocks A1 and A2 then you can only charge one special
> I would also defer to your compliance officer in the hospital, because
> are the ones that will ultimately have to answer to the Feds.    I hope
> this is what you needed.
> Debbie J. Siena
> NSH Legislative Chair person
> Baylor University Medical Center
> Dallas, TX 75246
> 214-820-2465
> -----Original Message-----
> From: Robert Santoianni []
> Sent: Monday, February 21, 2000 1:56 PM
> To:
> Subject: Multiple CPT Code Billing
> Does anyone out there know if you can charge for identical special
> stains on the same specimen?  For example, AFB (88312) on blocks 1A and
> 1C.  Our admin. asst. says that you cannot bill for multiple identical
> special stains on a specimen.
> Bob Santoianni
> Emory University Hospital
> Atlanta, GA

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