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Pathologist Professional Component Billing for Clinical Pathology Services

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.
Supervising laboratory technical personnel and advising them 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 laboratory reports.
Assuring the hospital laboratory s compliance with State licensure and certification standards, Medicare conditions, voluntary accreditation standards, and Federal certification standards.

Pathologists should be compensated for these clinical pathology services. A variety of valid and accepted methods for paying for the above professional services of the pathologist in the hospital clinical laboratory are available.

These physician services may be billable by the pathologist to the patient (or the patient s insurer) or to the hospital. Medicare rules require pathologists to look to the hospital for the professional component of clinical pathology services to Medicare patients because the hospital s Medicare payment rate includes payment of 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 with the hospital billing 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 non-physician personnel -- it does not cover the professional services of the pathologist.

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