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Re: Droppong Clia Waver

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Elaine,If you don't do any CLIA-waived tests, then it makes no sense for you to pay for the waiver. If you do any CLIA-waived tests, you are required by law to get the waiver. The penalties, per CDC: Basis for imposing a civil money penalty. CMS may impose a

civil money penalty against any laboratory determined to have condition

level deficiencies regardless of whether those deficiencies pose

immediate jeopardy. ----- (2) Range of penalty amount.

(i) For a condition level deficiency that poses immediate jeopardy,

the range is $3,050-$10,000 per day of noncompliance or per violation.

(ii) For a condition level deficiency that does not pose immediate

jeopardy, the range is $50-$3,000 per day of noncompliance or per

violation.

I think it highly unlikely that you would get caught if you didn't have a waiver, but those are the risks you would be taking on. SetoSouth Pasadena, CA

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

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Elaine,I have a rule to never try to make sense out of government regulations; if you don't get more confused you're likely to get high blood pressure, or both! My understanding is that without a CLIA license you're not allowed to use the lab results clinically; microscopy by MD might be an exception! Not sure how anyone would care, but you might want to consider it in terms of risk assessment for malpractice. That may not be an issue for an IMP doing all office testing. Still probably won't get it paid!Subject: Droppong Clia WaverTo: "practiceimprovement1"

< >Date: Saturday, March 5, 2011, 9:57 PM

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

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Elaine,

You are likely not billing them

correctly. Are you putting the QW modifier on the lab codes? Are you putting

yourself down as Referring and Ordering Provider? Are you making sure that

only the correct ICD-9 codes are being used? Have you called Medicare and

asked why you aren’t being paid?

The reason to have your CLIA is to comply

with federal law, which states that you must have a license to collect bodily

fluids (or something to that effect). Get caught, and you could face $$$ in

fines. Chances of getting caught? I’m not sure. Being an ex-Federal

government employee, I’m not willing to break those rules myself, but to

each his own.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of

Sent: Saturday, March 05, 2011

9:58 PM

To: practiceimprovement1

Subject:

Droppong Clia Waver

I just

paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not

paying me for my labs- UA, strep throat, preg test, so why do i bother to

submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia.

Can anyone think of anything wrong w this strategy? Do I have any downside?

Next yr I think I will save the $150

--

M.D.

www.elainemd.com

Office:

Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly

confidential medical, Personal and Health Information (PHI) and/or legal

information. The information is intended only for the use of the individual or

entity named above.

If you are not the intended recipient of this material, you may not use,

publish, discuss, disseminate or otherwise distribute it. If you are not the

intended recipient, or if you have received this transmission in error, please

notify the sender immediately and confidentially destroy the information that

email in error.

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Only in America do you need to pay $150 to get a piece of paper that says you won't be doing any point of care testing more complicated than a urine pregnancy test. The scale of the penalty amounts is ridiculous. The government interference in healthcare is out of control.Ben

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

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Totally agree. But I guess i am stuck spending the $150...just another tax I guess. The city of Glendale even taxes my belongings. everything in my office is taxed every year on its value

 

Only in America do you need to pay $150  to get a piece of paper that says you won't be doing any point of care testing more complicated than a urine pregnancy test.  The scale of the penalty amounts is ridiculous.  The government interference in healthcare is out of control.

Ben

 

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

 If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

 If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

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You mean you need a clia waiver to do collect specimens too even if you dont do any onsite testing?

 

Totally agree. But I guess i am stuck spending the $150...just another tax I guess. The city of Glendale even taxes my belongings. everything in my office is taxed every year on its value

 

Only in America do you need to pay $150  to get a piece of paper that says you won't be doing any point of care testing more complicated than a urine pregnancy test.  The scale of the penalty amounts is ridiculous.  The government interference in healthcare is out of control.

Ben

 

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

 If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

 If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- Sangeetha

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You mean you need a clia waiver to do collect specimens too even if you dont do any onsite testing?

 

Totally agree. But I guess i am stuck spending the $150...just another tax I guess. The city of Glendale even taxes my belongings. everything in my office is taxed every year on its value

 

Only in America do you need to pay $150  to get a piece of paper that says you won't be doing any point of care testing more complicated than a urine pregnancy test.  The scale of the penalty amounts is ridiculous.  The government interference in healthcare is out of control.

Ben

 

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

 If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

 If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- Sangeetha

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Guest guest

You mean you need a clia waiver to do collect specimens too even if you dont do any onsite testing?

 

Totally agree. But I guess i am stuck spending the $150...just another tax I guess. The city of Glendale even taxes my belongings. everything in my office is taxed every year on its value

 

Only in America do you need to pay $150  to get a piece of paper that says you won't be doing any point of care testing more complicated than a urine pregnancy test.  The scale of the penalty amounts is ridiculous.  The government interference in healthcare is out of control.

Ben

 

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

 If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above.

 If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- Sangeetha

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Guest guest

I think if you are only collecting

specimens (such as paps) and sending them out to a lab you do not need a

waiver. But any in-office “lab” that you do requires a CLIA Certificate, even

if it is a UA Pregnancy test. Most small offices stick with the Waiver, because

to run a full ‘lab’ is super-expensive (in fees to CLIA and the State, not to

mention the cost of the lab supplies). Offices that have a Clia-Waived certificate

must do CLIA-waived tests only.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of Sangeetha Murthy

Sent: Monday, March 07, 2011 7:35

AM

To:

Subject: Re:

Droppong Clia Waver

You mean you need a clia waiver to do collect

specimens too even if you dont do any onsite testing?

Totally agree. But I guess i am stuck spending the

$150...just another tax I guess. The city of Glendale even taxes my belongings. everything

in my office is taxed every year on its value

On Sun, Mar 6, 2011 at 12:25 PM, Ben Brewer

wrote:

Only in America do you need to pay $150 to get

a piece of paper that says you won't be doing any point of care testing more

complicated than a urine pregnancy test. The scale of the penalty

amounts is ridiculous. The government interference in healthcare is out

of control.

Ben

I just paid $150 for my clia waver. Not sure why I

meed to do this. Medicare is not paying me for my labs- UA, strep throat,

preg test, so why do i bother to submit. I don't even bill up to $150 anyway.

Private ins does not ask for Clia. Can anyone think of anything wrong w this

strategy? Do I have any downside? Next yr I think I will save the $150

--

M.D.

www.elainemd.com

Office:

Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly

confidential medical, Personal and Health Information (PHI) and/or legal

information. The information is intended only for the use of the individual

or entity named above.

If you are not the intended recipient of this material, you may not use,

publish, discuss, disseminate or otherwise distribute it. If you are not the

intended recipient, or if you have received this transmission in error,

please notify the sender immediately and confidentially destroy the

information that email in error.

--

M.D.

www.elainemd.com

Office:

Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly

confidential medical, Personal and Health Information (PHI) and/or legal

information. The information is intended only for the use of the individual or

entity named above.

If you are not the intended recipient of this material, you may not use,

publish, discuss, disseminate or otherwise distribute it. If you are not the

intended recipient, or if you have received this transmission in error, please

notify the sender immediately and confidentially destroy the information that

email in error.

--

Sangeetha

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Guest guest

I think if you are only collecting

specimens (such as paps) and sending them out to a lab you do not need a

waiver. But any in-office “lab” that you do requires a CLIA Certificate, even

if it is a UA Pregnancy test. Most small offices stick with the Waiver, because

to run a full ‘lab’ is super-expensive (in fees to CLIA and the State, not to

mention the cost of the lab supplies). Offices that have a Clia-Waived certificate

must do CLIA-waived tests only.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of Sangeetha Murthy

Sent: Monday, March 07, 2011 7:35

AM

To:

Subject: Re:

Droppong Clia Waver

You mean you need a clia waiver to do collect

specimens too even if you dont do any onsite testing?

Totally agree. But I guess i am stuck spending the

$150...just another tax I guess. The city of Glendale even taxes my belongings. everything

in my office is taxed every year on its value

On Sun, Mar 6, 2011 at 12:25 PM, Ben Brewer

wrote:

Only in America do you need to pay $150 to get

a piece of paper that says you won't be doing any point of care testing more

complicated than a urine pregnancy test. The scale of the penalty

amounts is ridiculous. The government interference in healthcare is out

of control.

Ben

I just paid $150 for my clia waver. Not sure why I

meed to do this. Medicare is not paying me for my labs- UA, strep throat,

preg test, so why do i bother to submit. I don't even bill up to $150 anyway.

Private ins does not ask for Clia. Can anyone think of anything wrong w this

strategy? Do I have any downside? Next yr I think I will save the $150

--

M.D.

www.elainemd.com

Office:

Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly

confidential medical, Personal and Health Information (PHI) and/or legal

information. The information is intended only for the use of the individual

or entity named above.

If you are not the intended recipient of this material, you may not use,

publish, discuss, disseminate or otherwise distribute it. If you are not the

intended recipient, or if you have received this transmission in error,

please notify the sender immediately and confidentially destroy the

information that email in error.

--

M.D.

www.elainemd.com

Office:

Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly

confidential medical, Personal and Health Information (PHI) and/or legal

information. The information is intended only for the use of the individual or

entity named above.

If you are not the intended recipient of this material, you may not use,

publish, discuss, disseminate or otherwise distribute it. If you are not the

intended recipient, or if you have received this transmission in error, please

notify the sender immediately and confidentially destroy the information that

email in error.

--

Sangeetha

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Guest guest

I think if you are only collecting

specimens (such as paps) and sending them out to a lab you do not need a

waiver. But any in-office “lab” that you do requires a CLIA Certificate, even

if it is a UA Pregnancy test. Most small offices stick with the Waiver, because

to run a full ‘lab’ is super-expensive (in fees to CLIA and the State, not to

mention the cost of the lab supplies). Offices that have a Clia-Waived certificate

must do CLIA-waived tests only.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of Sangeetha Murthy

Sent: Monday, March 07, 2011 7:35

AM

To:

Subject: Re:

Droppong Clia Waver

You mean you need a clia waiver to do collect

specimens too even if you dont do any onsite testing?

Totally agree. But I guess i am stuck spending the

$150...just another tax I guess. The city of Glendale even taxes my belongings. everything

in my office is taxed every year on its value

On Sun, Mar 6, 2011 at 12:25 PM, Ben Brewer

wrote:

Only in America do you need to pay $150 to get

a piece of paper that says you won't be doing any point of care testing more

complicated than a urine pregnancy test. The scale of the penalty

amounts is ridiculous. The government interference in healthcare is out

of control.

Ben

I just paid $150 for my clia waver. Not sure why I

meed to do this. Medicare is not paying me for my labs- UA, strep throat,

preg test, so why do i bother to submit. I don't even bill up to $150 anyway.

Private ins does not ask for Clia. Can anyone think of anything wrong w this

strategy? Do I have any downside? Next yr I think I will save the $150

--

M.D.

www.elainemd.com

Office:

Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly

confidential medical, Personal and Health Information (PHI) and/or legal

information. The information is intended only for the use of the individual

or entity named above.

If you are not the intended recipient of this material, you may not use,

publish, discuss, disseminate or otherwise distribute it. If you are not the

intended recipient, or if you have received this transmission in error,

please notify the sender immediately and confidentially destroy the

information that email in error.

--

M.D.

www.elainemd.com

Office:

Go in the directions of your dreams and live the life you've imagined.

This email transmission may contain protected and privileged, highly

confidential medical, Personal and Health Information (PHI) and/or legal

information. The information is intended only for the use of the individual or

entity named above.

If you are not the intended recipient of this material, you may not use,

publish, discuss, disseminate or otherwise distribute it. If you are not the

intended recipient, or if you have received this transmission in error, please

notify the sender immediately and confidentially destroy the information that

email in error.

--

Sangeetha

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Guest guest

I disagree very much. Again the whole set of problems surrounding the PAP's in the '70's is exactly why the CLIA Act was passed in the first place. And proper collection, chain of custody, documentation are all part of what brought it about.... And were glaring problems that were brought to light. It was a real food fight as the layers of mistakes slowly peeled away. I personally would not collect PAP's or other samples for labs without a certificate in place. Each state runs their own CLIA program much like many other things ordered by the Feds but allowed some differences from state to state. A state may NOT water down or have more lenient rules but any state is welcome and encouraged to enact "Better and more Stringent" standards and enforcement. So in the end I would say web search your own state

gov't and make sure what the rules are in your particular state... NYS is one of the stricter states enjoying ramping up on docs and businesses any chance they can get....

To: Sent: Mon, March 7, 2011 11:06:04 AMSubject: RE: Droppong Clia Waver

I think if you are only collecting specimens (such as paps) and sending them out to a lab you do not need a waiver. But any in-office “lab†that you do requires a CLIA Certificate, even if it is a UA Pregnancy test. Most small offices stick with the Waiver, because to run a full ‘lab’ is super-expensive (in fees to CLIA and the State, not to mention the cost of the lab supplies). Offices that have a Clia-Waived certificate must do CLIA-waived tests only.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of Sangeetha MurthySent: Monday, March 07, 2011 7:35 AMTo: Subject: Re: Droppong Clia Waver

You mean you need a clia waiver to do collect specimens too even if you dont do any onsite testing?

Totally agree. But I guess i am stuck spending the $150...just another tax I guess. The city of Glendale even taxes my belongings. everything in my office is taxed every year on its value

Only in America do you need to pay $150 to get a piece of paper that says you won't be doing any point of care testing more complicated than a urine pregnancy test. The scale of the penalty amounts is ridiculous. The government interference in healthcare is out of control.

Ben

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above. If you are not the intended

recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above. If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- Sangeetha

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Guest guest

I disagree very much. Again the whole set of problems surrounding the PAP's in the '70's is exactly why the CLIA Act was passed in the first place. And proper collection, chain of custody, documentation are all part of what brought it about.... And were glaring problems that were brought to light. It was a real food fight as the layers of mistakes slowly peeled away. I personally would not collect PAP's or other samples for labs without a certificate in place. Each state runs their own CLIA program much like many other things ordered by the Feds but allowed some differences from state to state. A state may NOT water down or have more lenient rules but any state is welcome and encouraged to enact "Better and more Stringent" standards and enforcement. So in the end I would say web search your own state

gov't and make sure what the rules are in your particular state... NYS is one of the stricter states enjoying ramping up on docs and businesses any chance they can get....

To: Sent: Mon, March 7, 2011 11:06:04 AMSubject: RE: Droppong Clia Waver

I think if you are only collecting specimens (such as paps) and sending them out to a lab you do not need a waiver. But any in-office “lab†that you do requires a CLIA Certificate, even if it is a UA Pregnancy test. Most small offices stick with the Waiver, because to run a full ‘lab’ is super-expensive (in fees to CLIA and the State, not to mention the cost of the lab supplies). Offices that have a Clia-Waived certificate must do CLIA-waived tests only.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of Sangeetha MurthySent: Monday, March 07, 2011 7:35 AMTo: Subject: Re: Droppong Clia Waver

You mean you need a clia waiver to do collect specimens too even if you dont do any onsite testing?

Totally agree. But I guess i am stuck spending the $150...just another tax I guess. The city of Glendale even taxes my belongings. everything in my office is taxed every year on its value

Only in America do you need to pay $150 to get a piece of paper that says you won't be doing any point of care testing more complicated than a urine pregnancy test. The scale of the penalty amounts is ridiculous. The government interference in healthcare is out of control.

Ben

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above. If you are not the intended

recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above. If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- Sangeetha

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I disagree very much. Again the whole set of problems surrounding the PAP's in the '70's is exactly why the CLIA Act was passed in the first place. And proper collection, chain of custody, documentation are all part of what brought it about.... And were glaring problems that were brought to light. It was a real food fight as the layers of mistakes slowly peeled away. I personally would not collect PAP's or other samples for labs without a certificate in place. Each state runs their own CLIA program much like many other things ordered by the Feds but allowed some differences from state to state. A state may NOT water down or have more lenient rules but any state is welcome and encouraged to enact "Better and more Stringent" standards and enforcement. So in the end I would say web search your own state

gov't and make sure what the rules are in your particular state... NYS is one of the stricter states enjoying ramping up on docs and businesses any chance they can get....

To: Sent: Mon, March 7, 2011 11:06:04 AMSubject: RE: Droppong Clia Waver

I think if you are only collecting specimens (such as paps) and sending them out to a lab you do not need a waiver. But any in-office “lab†that you do requires a CLIA Certificate, even if it is a UA Pregnancy test. Most small offices stick with the Waiver, because to run a full ‘lab’ is super-expensive (in fees to CLIA and the State, not to mention the cost of the lab supplies). Offices that have a Clia-Waived certificate must do CLIA-waived tests only.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of Sangeetha MurthySent: Monday, March 07, 2011 7:35 AMTo: Subject: Re: Droppong Clia Waver

You mean you need a clia waiver to do collect specimens too even if you dont do any onsite testing?

Totally agree. But I guess i am stuck spending the $150...just another tax I guess. The city of Glendale even taxes my belongings. everything in my office is taxed every year on its value

Only in America do you need to pay $150 to get a piece of paper that says you won't be doing any point of care testing more complicated than a urine pregnancy test. The scale of the penalty amounts is ridiculous. The government interference in healthcare is out of control.

Ben

I just paid $150 for my clia waver. Not sure why I meed to do this. Medicare is not paying me for my labs- UA, strep throat, preg test, so why do i bother to submit. I don't even bill up to $150 anyway. Private ins does not ask for Clia. Can anyone think of anything wrong w this strategy? Do I have any downside? Next yr I think I will save the $150-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above. If you are not the intended

recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- M.D.www.elainemd.comOffice: Go in the directions of your dreams and live the life you've imagined.This email transmission may contain protected and privileged, highly confidential medical, Personal and Health Information (PHI) and/or legal information. The information is intended only for the use of the individual or entity named above. If you are not the intended recipient of this material, you may not use, publish, discuss, disseminate or otherwise distribute it. If you are not the intended recipient, or if you have received this transmission in error, please notify the sender immediately and confidentially destroy the information that email in error.

-- Sangeetha

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Guest guest

No, CLIA is for labs only, not collection

of specimens. I do not see anything in our State guidelines or CMS guidelines

that specifies that you have to have a CLIA waiver to collect specimens. ,

if you can provide proof otherwise, please enlighten us; we have a waiver, so

it doesn’t much matter to me, but it may to others. Everything surrounding

CLIA refers to labs/tests

performed in-house. From: https://www.cms.gov/CLIA/downloads/HowObtainCLIACertificate.pdf

DO

I NEED TO HAVE A CLIA CERTIFICATE?

CLIA

requires all facilities that perform even one test, including waived

tests,

on “materials derived from the human body for the purpose of

providing

information for the diagnosis, prevention, or treatment of any

disease

or impairment of, or the assessment of the health of, human

beings”

to meet certain Federal requirements. If a facility performs tests

for

these purposes, it is considered a laboratory under CLIA and must

apply

and obtain a certificate from the CLIA program that corresponds

to the complexity of tests performed.

My interpretation of this is that if you

are simply collecting the specimen, but are not doing any testing on it, you

are NOT required to have a CLIA certificate.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of Bleiweiss

Sent: Monday, March 07, 2011 8:14

AM

To:

Subject: Re:

Droppong Clia Waver

I disagree very much. Again the whole set of problems

surrounding the PAP's in the '70's is exactly why the CLIA Act was passed in

the first place. And proper collection, chain of custody, documentation are all

part of what brought it about.... And were glaring problems that were brought

to light. It was a real food fight as the layers of mistakes slowly peeled

away. I personally would not collect PAP's or other samples for labs without a

certificate in place. Each state runs their own CLIA program much like many

other things ordered by the Feds but allowed some differences from state to

state. A state may NOT water down or have more lenient rules but any state is

welcome and encouraged to enact " Better and more Stringent " standards

and enforcement. So in the end I would say web search your own state gov't and

make sure what the rules are in your particular state... NYS is one of the

stricter states enjoying ramping up on docs and businesses any chance they can

get....

From: Pratt

To:

Sent: Mon, March 7, 2011 11:06:04

AM

Subject: RE:

Droppong Clia Waver

I think if you are only collecting specimens (such as paps) and

sending them out to a lab you do not need a waiver. But any in-office

“lab” that you do requires a CLIA Certificate, even if it is a UA Pregnancy

test. Most small offices stick with the Waiver, because to run a full

‘lab’ is super-expensive (in fees to CLIA and the State, not to mention the

cost of the lab supplies). Offices that have a Clia-Waived certificate

must do CLIA-waived tests only.

Link to comment
Share on other sites

Guest guest

No, CLIA is for labs only, not collection

of specimens. I do not see anything in our State guidelines or CMS guidelines

that specifies that you have to have a CLIA waiver to collect specimens. ,

if you can provide proof otherwise, please enlighten us; we have a waiver, so

it doesn’t much matter to me, but it may to others. Everything surrounding

CLIA refers to labs/tests

performed in-house. From: https://www.cms.gov/CLIA/downloads/HowObtainCLIACertificate.pdf

DO

I NEED TO HAVE A CLIA CERTIFICATE?

CLIA

requires all facilities that perform even one test, including waived

tests,

on “materials derived from the human body for the purpose of

providing

information for the diagnosis, prevention, or treatment of any

disease

or impairment of, or the assessment of the health of, human

beings”

to meet certain Federal requirements. If a facility performs tests

for

these purposes, it is considered a laboratory under CLIA and must

apply

and obtain a certificate from the CLIA program that corresponds

to the complexity of tests performed.

My interpretation of this is that if you

are simply collecting the specimen, but are not doing any testing on it, you

are NOT required to have a CLIA certificate.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of Bleiweiss

Sent: Monday, March 07, 2011 8:14

AM

To:

Subject: Re:

Droppong Clia Waver

I disagree very much. Again the whole set of problems

surrounding the PAP's in the '70's is exactly why the CLIA Act was passed in

the first place. And proper collection, chain of custody, documentation are all

part of what brought it about.... And were glaring problems that were brought

to light. It was a real food fight as the layers of mistakes slowly peeled

away. I personally would not collect PAP's or other samples for labs without a

certificate in place. Each state runs their own CLIA program much like many

other things ordered by the Feds but allowed some differences from state to

state. A state may NOT water down or have more lenient rules but any state is

welcome and encouraged to enact " Better and more Stringent " standards

and enforcement. So in the end I would say web search your own state gov't and

make sure what the rules are in your particular state... NYS is one of the

stricter states enjoying ramping up on docs and businesses any chance they can

get....

From: Pratt

To:

Sent: Mon, March 7, 2011 11:06:04

AM

Subject: RE:

Droppong Clia Waver

I think if you are only collecting specimens (such as paps) and

sending them out to a lab you do not need a waiver. But any in-office

“lab” that you do requires a CLIA Certificate, even if it is a UA Pregnancy

test. Most small offices stick with the Waiver, because to run a full

‘lab’ is super-expensive (in fees to CLIA and the State, not to mention the

cost of the lab supplies). Offices that have a Clia-Waived certificate

must do CLIA-waived tests only.

Link to comment
Share on other sites

Guest guest

No, CLIA is for labs only, not collection

of specimens. I do not see anything in our State guidelines or CMS guidelines

that specifies that you have to have a CLIA waiver to collect specimens. ,

if you can provide proof otherwise, please enlighten us; we have a waiver, so

it doesn’t much matter to me, but it may to others. Everything surrounding

CLIA refers to labs/tests

performed in-house. From: https://www.cms.gov/CLIA/downloads/HowObtainCLIACertificate.pdf

DO

I NEED TO HAVE A CLIA CERTIFICATE?

CLIA

requires all facilities that perform even one test, including waived

tests,

on “materials derived from the human body for the purpose of

providing

information for the diagnosis, prevention, or treatment of any

disease

or impairment of, or the assessment of the health of, human

beings”

to meet certain Federal requirements. If a facility performs tests

for

these purposes, it is considered a laboratory under CLIA and must

apply

and obtain a certificate from the CLIA program that corresponds

to the complexity of tests performed.

My interpretation of this is that if you

are simply collecting the specimen, but are not doing any testing on it, you

are NOT required to have a CLIA certificate.

Pratt

Office Manager

Oak Tree Internal Medicine P.C

www.prattmd.info

From: [mailto: ] On Behalf Of Bleiweiss

Sent: Monday, March 07, 2011 8:14

AM

To:

Subject: Re:

Droppong Clia Waver

I disagree very much. Again the whole set of problems

surrounding the PAP's in the '70's is exactly why the CLIA Act was passed in

the first place. And proper collection, chain of custody, documentation are all

part of what brought it about.... And were glaring problems that were brought

to light. It was a real food fight as the layers of mistakes slowly peeled

away. I personally would not collect PAP's or other samples for labs without a

certificate in place. Each state runs their own CLIA program much like many

other things ordered by the Feds but allowed some differences from state to

state. A state may NOT water down or have more lenient rules but any state is

welcome and encouraged to enact " Better and more Stringent " standards

and enforcement. So in the end I would say web search your own state gov't and

make sure what the rules are in your particular state... NYS is one of the

stricter states enjoying ramping up on docs and businesses any chance they can

get....

From: Pratt

To:

Sent: Mon, March 7, 2011 11:06:04

AM

Subject: RE:

Droppong Clia Waver

I think if you are only collecting specimens (such as paps) and

sending them out to a lab you do not need a waiver. But any in-office

“lab” that you do requires a CLIA Certificate, even if it is a UA Pregnancy

test. Most small offices stick with the Waiver, because to run a full

‘lab’ is super-expensive (in fees to CLIA and the State, not to mention the

cost of the lab supplies). Offices that have a Clia-Waived certificate

must do CLIA-waived tests only.

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Share on other sites

Guest guest

I agree it doesn't make sense that physicians have to pay $150.00 for some of the CLIA waived tests. For me, the logic is off. It is ok for a pt to bring in the results of their glucometer and interim adjustments in their medication can be based on those reported values. Yet, if a physician does a glucometer reading in their office...that value can't be used for documentation and/or test can't be charged for unless one has paid for a CLIA certificate.

By the way, thanks for the reminder and brief recap about the pap scandal. I remember that also.

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