Lab receives the slides and registers the patient. Pathology then takes over, reviews the slides, submits a report, etc. and bills the patient in their separate billing system. The hospital hasn't been billing any charges. Should we?
Yes, if a hospital lab is performing the tests and has technical expense (such as technicians, supplies, or equipment) to do so, the hospital should bill CPTs 88321, 88323, and 88325. If the lab is not part of the hospital, this could be more complicated. See Section 20.4 of https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c06.pdf. for outpatient labs. See Section 50 of https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c01.pdf for inpatient labs.
Thanks! The Pathology Group is housed within the hospital. All specimens are received by the hospital. The hospital staff registers the patient and then walks the slides across that hall to Pathology. That's it.
I would recommend double-checking that that location is a hospital department, claimed as such on the Cost Report, just to make sure.