November 2018 Webinar Q&A: Billing Updates and Reminders for 2019

Thank you for joining our Billing Updates and Reminders for 2019 Webinar Q&A Webinar. We appreciated your participation, and thank you all for the questions. To watch the webinar, please visit our Educational Videos section.

Questions from the webinar are answered below:

Q:  Can NeoGenomics bill molecular testing to any insurance payer (BCBS, Medicare, Humana, Aetna, etc.) on an inpatient or is that always billed back to the hospital?

A:  If the patient is an inpatient, and the payer follows CMS guidelines, NeoGenomics will bill the hospital for molecular testing that is ordered within 14 days of discharge.  If the payer does not follow CMS guidelines, then NeoGenomics can bill the molecular testing to the payer directly on an inpatient.

Q:  What happens if the physician’s signature is not on the requisition?

A:  If the physician signature or documentation to support the medical necessity of the testing ordered is not received, NeoGenomics will be required to contact the ordering facility to obtain a copy of this patient record if requested by CMS. Having the physician signature on the requisition at the time the testing is submitted, will save time and aggravation for the facility staff down the road if this is required.

Q:  How is molecular testing billed for outpatients that are on Medicaid?

A:  At this time, NeoGenomics only applies the CMS OPPS rule to Medicare and Medicare Advantage plans, so if the patient has a Medicaid plan (that does not follow CMS Guidelines) we would be billing Medicaid directly for the molecular testing.

Q:  Can NeoGenomics just identify what the correct ICD-10 code should be if we submit a pathology report?

A: Since NeoGenomics is not the licensed healthcare provider ordering the test, nor knows the specific reasoning why the testing is being ordered, it is the responsibility of the client to provide the diagnosis information as either an ICD-10 code or narrative diagnosis.

Q:  If we are a physician practice, do we need to provide the “Specimen Origin” and “Bill to” information on every requisition?

A:  Yes, the “Specimen Origin” and “Bill to” information must be provided on every requisition. 

Q:  Is the ICD-10 code or narrative diagnosis only required for government plans?

A:  An ICD-10 code or narrative diagnosis is required for NeoGenomics to bill any 3rd party payer to support the medical necessity of the testing ordered.

Q:  If we are billed for a case that should have been billed to Medicare, what should we do?

A:  Please contact our Billing Department so that we may review the case and bill Medicare accordingly.

Q:  What is the difference between a National and a Local Coverage Determination? 

A:  A national coverage determination is made through an evidence-based process with opportunities for public participation.   In the absence of a national coverage policy, an item or service may be covered at the discretion of a Medicare contractor based on a local coverage determination.

Q:  Is the signature date important?

A:  Yes, as it indicates the actual date the testing is ordered.

Q:  I get confused about whether a patient is considered an inpatient, outpatient or non-hospital patient.  Can you explain what each are?

A:  An inpatient is a patient who is formally admitted to a hospital with a doctor’s order for an inpatient hospital admission.  The patient’s stay typically lasts more than 24 hours.  An outpatient is a patient who gets outpatient surgery, lab tests or other hospital services and the doctor has not written an order to admit the patient as an inpatient.  A non-hospital patient is a patient who has a specimen submitted for testing but is not physically at the hospital.  The patient’s status would be non-hospital if the specimen is sent from a physician’s office, or is an archived specimen (specimen sent 14+ days post discharge).  

Q: What happens if we do not provide the ICD-10 code or narrative diagnosis on the requisition form?

A:  NeoGenomics must then contact the ordering healthcare provider to obtain the code or the diagnosis, a burdensome and time-consuming task for both client and NeoGenomics.    

Q:  If we order a NeoType Profile for a Medicare outpatient which has both molecular and non-molecular tests, how will the tests be billed?

A: The molecular testing will be billed to Medicare directly along with any of the applicable professional components of the non-molecular tests.  The technical components of the non-molecular tests will still be billed back to the hospital if the testing was ordered within 14 days of discharge.

Q:  Are stamped signatures permitted?

A:  CMS allows stamped signatures only if the ordering physician has a physical disability and can prove to a CMS contractor that he or she is not able to sign due to that disability. 

Q: If the test performed require an authorization who would get that? Do you do a benefit investigation on all patients?

A: Many of the insurance carriers that are requiring prior authorizations on molecular testing also require that the ordering physician complete the authorization process, and state that the reference laboratory cannot obtain the prior authorization on the physicians behalf.  However, there are a few insurance carriers that NeoGenomics can attempt to obtain prior authorization from, which we do attempt to do if a prior authorization is not received with the patient’s specimen.

Q: How do we mark the requisition if we want all the testing billed back to our facility, but it’s an outpatient so the molecular testing needs to be billed to Medicare? 

A: On test requisitions and in online ordering, we have a Bill To option of “Outpatient Molecular to Medicare; all other testing to client”.  If that bill to is marked, and the patient status of patient is outpatient is selected; we will bill only the outpatient Molecular testing to Medicare; and any additional testing will be billed back to the client directly.

Q: How do we need to mark the requisition to make sure you bill Medicare for the Molecular testing on an outpatient?

A: If the Medicare, Insurance, Split Billing, or Outpatient Molecular to MCR; all other testing to client Bill to options are chosen; and the patient status is marked as outpatient NeoGenomics will be billing the Molecular testing directly to CMS.

Q: Is the 14 day rule only for Medicare patients? Are you using the 14 day rule for commercial insurance too?

A: The 14-Day rule for Molecular outpatient testing does only apply to molecular testing ordered on a hospital outpatient for Medicare and Medicare Advantage plans.  If the patient has a commercial plan such as United HealthCare or Humana, both of which follow CMS guidelines, and the patient is an outpatient, molecular testing ordered would still be billed back to the hospital if the patient does not have a Medicare Advantage plan.

Q: We were under the impression the 14-day rule is no longer applicable today.  Is this not accurate?

A: The 14 Day rule for OPPS is still in effect. What happened is that CMS extended the enforcement date in order to provide laboratories and hospitals time to implement the changes needed in order to comply with the ruling.  For more information, CMS has created a separate webpage located at

Q: Do you follow Medicare's 14 day rule for Medicare Advantage plans also?

A: Yes, we are applying the 14 Day rule to Medicare, as well as Medicare Advantage plans.

Q: Signatures: would the sending pathologist or the ordering physician need to sign, or can either?

A: Whomever is ordering the testing would need to sign the requisition or provide documentation attesting to the medical necessity of the testing.

Q: How will Neo bill the OP molecular if we mark bill to: insurance

A: If Insurance is marked on the requisition, our team looks to the insurance that was provided in order to determine how the outpatient Molecular would be billed.  If the patient has a Medicare or Medicare Advantage plan, we would bill the molecular to the payer directly.  If the patient has an insurance plan that follows Medicare guidelines (such as UHC or Humana), then the molecular testing would be billed back to the client directly.  If the patient has an insurance plan that does not follow Medicare guidelines, then the molecular testing would be billed to the payer directly.

Q: My understanding about 14 day rule it that one of the most important dates if the date the tests were ordered.  THAT date has to be later than 14 days after discharge.  The date testing performed is irrelevant. 

A: There are really two 14-day rules in effect right now with CMS.  The first rule, in regards to archived or stored specimens, applies to all methodologies of testing (FISH, FLOW, IHC, Cytogenetics and Molecular) where if the testing is ordered 14 or more days from patient discharge (applies to hospital inpatients and hospital outpatients), then the performing laboratory can bill all the testing ordered to CMS directly. The second rule, which applies to Molecular testing only performed on hospital outpatients, is for testing ordered between days 1-13 of patient discharge, and per the rule the performing laboratory must bill CMS directly, and the date of service of that testing is updated from the date the specimen was collected, to the date that the testing was performed.

Q: Did I understand correctly that NeoGenomics will apply the date of service exception rules to all patients with Medicare Advantage plans? 

A: Yes, if the patient has a Medicare Advantage plan, we are applying the CMS OPPS 14 day rule for the molecular charges that were ordered on hospital outpatient specimens.

Q: Is this signature requirement a new thing for 2019?  We've never been contacted by Neo for a missing signature, yet I know many are sent in without a signature.

A: No, the physician signature requirement is not new for 2019 and has been an Office of Inspector General (OIG) and CMS requirement for quite some time. A link to the most recent CMS publication can be found at:

Q: For a physician signature for online ordering: Are there any changes to this? Or is an electronic signature accepted?

A: No, there are no changes needed to Online Ordering at this time.  The online order is considered an electronic signature.

Q: How is LCD for Iowa vs LCD for Florida work?

A: The NCD/LCD that should be referenced when testing is being sent to NeoGenomics for testing is the NeoGenomics site where the specimen is being sent and performed.  So if the specimen is being sent to NeoGenomics Florida location, the LCD for Florida should be referenced.  If the testing is being sent to NeoGenomics Aliso Viejo location, then the LCD for Southern California should be referenced.

Q: Just confirming the updated CPT codes will be sent out in writing?

A: Yes, we will be sending out a client communication in the next couple of weeks which will include the updated CPT Codes for 2019.

Q: Please review the "split bill" option on the requisition & online ordering

A: Split Billing is the option for clients to designate that on that patients case, they would like all of the Technical Components billed back to the client/hospital, and the Professional components only billed to the patient’s insurance.  We have several clients who utilize this option as it allows them to know what charges to expect on every patients case.  With the 14-Day OPPS rule though, NeoGenomics will be billing out the Outpatient Molecular directly to Medicare or Medicare Advantage plans if the patient is covered under those insurance carriers.

Q: We have a case that is 2 years old and sending out for a FISH panel.  The patient has Medicaid.  Would Neo do the billing?

A: If the patients Medicaid Plan does not follow CMS guidelines, and if the plan does follow CMS guidelines, but the patient has not been readmitted to the hospital within 14 days of the testing being ordered, then NeoGenomics would bill the patients Medicaid plan directly.

Q: How often do we see our requisition forms update?  Is there a normal cadence?

A: Our requisition forms are updated as needed, but typically about once a quarter to allow for updates in our test menu.

Q: I have a NeoGenomics billing flow chart from 2017, is there a more current one?

A: Yes, we recently published a new one in September.  Please contact our client billing team ( or the Territory Business Manager that covers your account and they will provide you with a copy.

Q: Will NeoGenomics accept Medicaid billing?     

A: Yes, we accept all insurance plans.

Q: If MOM is selected on the req. will NEO determine if it is molecular and bill appropriately? Example: If a FISH is ordered and a molecular, will Neo determine billing on both of those tests i.e. client bill vs. third party bill

A: Yes, our system is configured to determine which testing needs to be client billed and what testing should be billed out to an insurance carrier directly for the 14-Day OPPS rule.

Q: When marking the requisition for an outpatient Medicare HMO, which insurance option should be selected?

A: Either Medicare or Insurance Bill can be marked on the requisition.  By marking either of these options, our billing team looks to the patient demographics provided to determine how the case should be billed.

Q: How do we process claims where Medicare is secondary?

A: Secondary Insurance would not come in to play with the rule change. If the patient has Medicare Primary insurance the rule would apply. If the patient has only Part A Medicare, with a secondary insurance to over Part B services, the secondary insurance would be considered a Medicare Advantage Plan which NeoGenomics is applying the rule change to as well. If the patient has commercial insurance as Primary Insurance, with Medicare secondary, then the rule change would not apply if the primary insurance is not a Medicare advantage plan.

Q: What time span is considered an archive specimen which would be considered a non-hospital patient?

A: An archived specimen, or stored specimen, is considered to be 14 or more days post discharge from the hospital.

Q: If we have an inpatient and a test is ordered over 14 days after discharge are they then considered an outpatient?

A: If testing is ordered 14 or more days after discharge, the specimen is then considered archived, which is treated as if it is a non-hospital specimen.

Q: How do we know what insurance plans follow Medicare Guidelines?

A: Please contact our client billing team ( or the Territory Business Manager that covers your account and they will provide you with a copy of our current list of payers.

Q: If pathology receives a signed order from a clinician can we submit that (along with the requisition) in lieu of the Neo requisition being signed?

A: Yes, a signed order from the clinician can be used to verify the medical necessity of the testing as long as the signed order from the clinician is for the testing that is being ordered.

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