A Program Memo issued by CMS (at the time known as HCFA) which addresses laboratory billing by both independent and provider-based RHCs, states:
Laboratory In light of recent inquiries regarding laboratory services, we are clarifying whether diagnostic laboratory tests furnished in the RHC/FQHC by their personnel are covered RHC/FQHC services paid under the all-inclusive rate, or whether such services are beyond the scope of RHC/FQHC services. While the law requires a facility seeking to be certified by Medicare as an RHC to provide routine diagnostic services, clinical diagnostic laboratory services are not within the scope of services covered and paid for under the RHC provisions.
Consequently, laboratory services (including the six required laboratory tests for RHC certification at 42 CFR §491.9) furnished by a clinic should be paid under the laboratory fee schedules. When clinics separately bill laboratory services, the cost of associated space, equipment, supplies, facility overhead and personnel for these services must be adjusted out of RHC/FQHC cost report. Furthermore, freestanding clinics should bill laboratory services to the Part B carrier and provider based clinics should bill these services to the fiscal intermediary that serves the main provider (e.g., the hospital’s intermediary).
The effective date of January 1, 2001 should be applied to implement this pronouncement to avoid the administrative burden of retroactively adjusting claims and cost reports.