Hospital laboratories must keep in mind the role they are playing when performing testing, Peter Kazon, an attorney with Alston & Bird, advised participants at Washington G-2 Report’s Lab Outreach Conference, held in San Diego June 8-10.

Different requirements will apply depending on whether the lab is acting as a hospital lab or as an outreach lab, he noted. For example, a hospital laboratory has to bundle testing while an outreach laboratory can bill Medicare directly.

Kazon also said that billing requirements for anatomic pathology services can vary depending on the role the lab is playing. For services provided to hospital outpatients, the pathologist would bill the professional component separately while the technical component would be billed and paid under the APC. For nonhospital, or outreach, patients, the hospital may be able to bill globally, depending on the arrangement with the pathologists.

For more on billing requirements and ways to minimize compliance risk in outreach testing, see the next issue of G-2 Compliance Report.