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Question: We are a primary care practice with a traveling phlebotomist and our own lab, and we have just learned about HCPCS code P9604. This code should allow us to bill for travel when the phlebotomist gets blood specimens from our house call patients. We have looked all over, even contacting our Medicare Administrative Contractor (MAC) to get clarification as to how to bill this code, but we cannot find anything that gives clear parameters about the flat rate portion. Is it saying if the phlebotomist travels more than 20 miles in a session that we have to bill per mile?

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Answer: The answer to your question is that you should not bill P9604 (Travel allowance one way in connection with medically necessary laboratory specimen collection drawn from home bound or nursing home bound patient; prorated trip charge.) to Medicare if your phlebotomist is traveling more than 20 miles to collect specimens.

Why? Per , the Centers for Medicare & Medicaid Services (CMS) 鈥減ays a travel allowance on the following bases: (1) flat-rate travel allowance; and (2) per-mile travel allowance,鈥� using P9604 or P9603 (Travel allowance one way in connection with medically necessary laboratory specimen collection drawn from home bound or nursing home bound patient; prorated miles actually travelled), respectively.

The manual goes on to tell you that you should bill P9604 鈥渨hen the trained technician travels 20 eligible miles or less to and from one location for specimen collection from one or more Medicare beneficiaries.鈥� The code is 鈥減rorated by the number of beneficiaries for whom a specimen collection fee is paid.鈥� Alternatively, you should bill P9603 鈥渨hen the round-trip travel to one location is greater than 20 eligible miles for specimen collection from one or more beneficiaries,鈥� or 鈥渨hen travel is to more than one location, regardless of the number of miles traveled.鈥�

So, if your phlebotomist is traveling more than 20 miles, or to more than one location, you should bill P9603. The total amount you bill (the mileage times the allowed mileage rate) should then be divided per beneficiary, and you should submit one claim per beneficiary for the divided amount.

Example: Your phlebotomist travels 45 miles to a skilled nursing facility (SNF), obtains blood specimens from six beneficiaries, then travels back to your practice. To calculate payment, you would multiply the total mileage (90) by the 2025 CMS travel allowance rate of $1.20 ($108.00). You would then divide that amount by the number of beneficiaries (6) and use that figure ($18) on one separate claim line for each beneficiary.

Bruce Pegg, BA, MA, CPC, CFPC, Managing Editor, AAPC