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CodeMap Compliance Briefing: 1/13/06
Many clinical laboratories place phlebotomists in referring physician practices to collect, process, and ship specimens to the laboratory. In many cases, the arrangement results in greater convenience for the physician practice's patients who no longer have to travel to a hospital, clinic, or drawing station to have their blood drawn. In addition, the process of delivering specimens to the laboratory is simplified because the laboratory phlebotomist is well trained in the specimen collection and handling requirements of the laboratory's testing. Although this arrangement has many advantages, laboratories and their referring clients must structure and maintain these relationships carefully to avoid implicating federal anti-kickback provisions. This week's briefing will discuss the potential problems associated with placing a laboratory-employed phlebotomist in a physician practice, as well as offer tips on how to remain in compliance with all r....
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