| Policy Synopsis
Pathologists perform professional services as well as technical services.
The variety of billing arrangements for pathologists’ services includes
professional component billing. In professional component billing, while
the hospital might bill the patient for the pathologist’s technical
services, the pathologist can bill the patient, the patient’s insurer,
or the hospital directly for professional services.
Policy
Quality laboratory services are essential to the diagnosis and treatment
of patients. Pathologist directors of hospital laboratories spend a significant
amount of time and effort in fulfilling their responsibility to the patient
for quality laboratory services. The pathologist is professionally responsible
and legally accountable for laboratory results. To prepare for this responsibility
the pathologist must complete a lengthy medical residency program. Moreover,
Federal certification standards and Joint Commission on Accreditation
of Healthcare Organizations standards require certain professional, organizational
and administrative services be provided in the clinical laboratory to
assure quality laboratory services to patients. The pathologist-director
of a hospital clinical laboratory provides professional services in:
- Assuring that tests, examinations, and procedures are properly performed,
recorded and reported;
- Interacting with members of the medical staff regarding issues of
laboratory operations, quality, and test availability;
- Designing protocols and establishing parameters for performance of
clinical testing;
- Recommending appropriate follow-up diagnostic tests, when appropriate;
- Supervising laboratory technicians and advising technicians regarding
aberrant results;
- Selecting, evaluating, and validating test methodologies;
- Directing, performing, and evaluating quality assurance and control
procedures;
- Evaluating clinical laboratory data and establishing a process for
review of test results prior to issuance of patient reports;
- Assuring the hospital laboratory’s compliance with state licensure
laws, Medicare conditions, Joint Commission on Accreditation of Healthcare
Organizations standards, the College of American Pathologists Laboratory
Accreditation Program and federal certification standards.
- A variety of valid and accepted methods for payment for the above
professional services of the pathologist in the hospital clinical laboratory
are available.
These physician services may be billed by the pathologist to the patient
(or the patient’s insurer) or to the hospital as the pathologist and hospital
may agree. Medicare rules require pathologists to seek payment from the
hospital for the professional component of clinical pathology services
to Medicare patients because the hospital’s Medicare payment rate includes
payment for these physician services. Pathologists and hospitals often
negotiate a different billing arrangement for the pathologist’s professional
services for non-Medicare patients. The pathologist may bill a professional
component for clinical laboratory services to the patient, and the hospital
may bill the technical component.
Professional component billing is one valid method of billing for the
professional services of pathologists in the clinical laboratory. In many
communities the standard practice is for the pathologist to direct bill
patients for the professional component of clinical laboratory services.
When the pathologist bills a professional component to a non-Medicare
patient, no payment is made by the hospital to the pathologist for this
service. The hospital’s bill for the technical component covers hospital
costs for laboratory equipment, supplies and non-physician personnel;
it does not cover the professional services of the pathologist.
Revision History
Adopted February 1991
Reaffirmed December 1992
Reaffirmed February 1996
Revised February 1999
Reaffirmed February 2002
|
|
|
