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The page below is a sample from the LabCE course Medicare Compliance for Clinical Laboratories. Access the complete course and earn ASCLS P.A.C.E.-approved continuing education credits by subscribing online.

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Phlebotomists and Equipment in Client Offices

Laboratories may place phlebotomists or other employees in a physician office if all of the following are done:

  • Employee only performs laboratory related tasks.
  • There is a written understanding given to the physician about what the employee can and cannot do.
  • Periodic audits are done to ensure the employee is following these policies.

Laboratories may place printers, computers, fax machines or other equipment or products in client offices as long as they ensure that:

  • The physician understands the equipment belongs to the laboratory.
  • It is used for laboratory purposes like receiving reports or ordering tests.
  • Periodic audits are done to ensure that the client is using the equipment only for laboratory related activities.