When Your Compliance Plan Hits a Sour Note
David M. Glaser, Esq.
January 15, 2026
Monitor Mondays listeners know that I end each segment with a song. Normally the topic drives the song, but to start the new year, the
Specimen collection can be an important part of performing respiratory therapy services. Which codes represent specimen collection services? There are several distinct codes for reporting these services. These include 36415, 36591, 36592, 36600, and 89220. Let’s review the fundamentals of each service to build success this year and beyond.
The first worth noting is Venipuncture. You can report the level I code 36415 to all payers including Medicare. Note that Medicare will reimburse for the venipuncture procedure once per encounter. One important factor to be aware of is to be sure to differentiate between venipuncture, capillary collection and draws from a line or access device. When collecting capillary specimens (36416), the related cost is considered by Medicare to be insignificant and should be bundled to the test procedure. For 2022, 36416 has again been assigned to status indicator “N,” meaning it is always packaged, and 36415 has been assigned to status indicator “Q4,” which means it will be conditionally packaged if billed on the same claim as a HCPCS code assigned a published status indicator “J1,” “J2,” “S,” “T,” “V,” “Q1,” “Q2,” or “Q3.” Understand that in other circumstances, payment will be made under the Clinical Laboratory Fee Schedule (CLFS). Do recognize that blood specimen collection performed during an IV start is not separately billable.
• For Venous Access Device (VAD), understand that code 36591 (collection of a blood specimen from a completely implantable VAD) can only be utilized when the VAD blood draw is from a completely implanted device, such as a Porta-Cath or Mediport. CPT® 36591 is designated as having a status indicator of “Q1.” A “Q1” is an “STV-packaged procedure.” Note that a procedure that has this designation may be separately reported to Medicare, but separate payment will be received only if no other status indicator “S,” “T,” or “V,” APC reimbursed procedure is billed on the same claim.
Know that CPT code 36592 should be assigned for blood draw from a PICC line or Hickman catheter. For 2022, code 36592 has been assigned to the same APC and status indicator as 36591. As stated above, the payment strategy referred to as “STV-packaged” codes means that conditions exist under which separate payment will be made, but when those conditions are not met, the payment will be packaged.
The codes assigned to a “Q1” status indicator will be paid separately when appearing on a claim without an “S,” “T,” or “V” procedure. Great concern exists by hospitals that question whether CPT codes 36591 and 36592 would ever be paid as their use is for the collection of blood specimens for laboratory testing. The AMA provided clarity by including a parenthetical note following each of these codes limiting their use with other laboratory services only.
When billing for arterial puncture specimen collection, report 36600. This CPT code holds a status indicator of “Q1” under the OPPS payment guidelines, meaning that, like the venous access device codes above, it will be paid separately when appearing on a claim without an “S,” “T,” or “V” procedure or separately through APC 5734. Note that this code is for the actual puncture of the artery; line draws are part of the continuum of care and not separately billable. The revenue center for blood specimen collection procedures should be 0300 unless instructed otherwise by the Part A/B MAC.
What about when it comes to sputum for diagnostic testing? Code 89220 is a covered service. The revenue code should be 0300, 0309, 0410, or 0419.
With the increase in “rapid screening tests” for respiratory syncytial virus (RSV) and influenza, MedLearn consultants have been receiving requests to provide CPT and billing instruction for collection of specimens via nasal lavage and suction. Unfortunately, there is no CPT or HCPCS code that represents the collection of this specimen. The cost is bundled into the cost of CPT codes 87631–87633.
Explore more billing tips and insight for respiratory CPT coding by ordering our Coding Essentials for RT/Pulmonary Function resource.
Monitor Mondays listeners know that I end each segment with a song. Normally the topic drives the song, but to start the new year, the
EDITOR’S NOTE: The author of this article used AI-assisted tools in its composition, but all content, analysis, and conclusions were based on the author’s professional
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