Labs, AP Groups Confused about UnitedHealthcare’s Test Registry

UHC plans webinars to explain steps it requires for labs, path groups to register their tests before Jan. 1

CONFUSION CONTINUES among clinical laboratories and anatomic pathology groups about how they should comply with UnitedHealthcare’s new Laboratory Test Registry Program.

The program goes into effect on Jan. 1, 2021, but labs and pathology groups must register all tests and testing procedures with UHC by Dec. 1, 2020. Since UHC announced the test registry in June, labs and anatomic pathology (AP) groups have struggled to understand how they should register their tests, according to experts who consult with labs and AP practices.

The level of confusion varies widely among labs and AP groups and is so widespread that UHC decided in Septemberto conduct webinars to help labs and AP practices understand the nuances of registering all clinical lab tests and AP procedures, which is required for labs to be paid for their test claims when UHC’s program becomes effective in January.

In an interview with The Dark Report, Leigh Polk, PathLab Marketing Specialist at Change Healthcare, said UHC’s webinars will run through March, raising questions about whether UHC will push back the implementation date of the new test registry program. Last summer, UHC moved the start date from Oct. 1 to Jan. 1, 2021.

UHC’s Laboratory Test Registry Program requires freestanding clinical or outpatient hospital labs to register all unique test codes and corresponding CPT codes by Dec. 1. The unique test code may be billed under single or multiple procedure codes effective Jan. 1, and all claims submitted must include the unique test code. UHC will deny claims if the test code does not match the corresponding test registration. (See “UHC Ready to Implement New Lab Test Registry” and “UHC Issues Details about How Labs Register Tests,” TDR, Aug. 3, 2020.)

“For the past few weeks, there was confusion about which labs and which places of services were affected,” Polk said. “All AP groups and clinical laboratories billing place of service 19, 22, or 81 are affected.”

Labs Have Many Questions

Diana Richard, Director of the Anatomic Pathology Program at XIFIN, a revenue practice management company for labs, said AP clients working with XIFIN also have questions. “We’ve been communicating with our 30 or so AP customers, who, combined, submit more than 100 million diagnostic claims each year,” she added. “Early on, there was much confusion, but now they understand what UHC expects, and we’re working with them to ensure the requirements are implemented cohesively for each party.”

Both Polk and Richard advise labs and AP groups to focus on registering their tests and to work closely with their billing companies when doing so. Polk said, “We recommend that all AP practices and clinical labs focus first on developing their test registration lists, and we will work with our lab and AP clients to ensure that the information in UHC’s test registration database matches what the labs will submit on their test claims.”

Change Healthcare has about 280 clinical lab and AP group clients. In addition to concern about which labs are affected, labs and AP groups also are worried about the increased administrative burden to register tests and then bill for those tests, added Polk.

Administrative Burden

“Not only does UHC’s lab test registry program increase the administrative burden on labs, but it also creates chaos for labs and AP groups as they prepare to comply with the program’s requirements,” she commented. Richard agreed, saying, “This requirement has created a massive administrative burden for all diagnostic providers and circumvents the AMA’s CPT coding process.”

The new identifiers that UHC requests were designed to be used for more discrete identification of proprietary and complex genetic testing services, she added. “The new codes don’t really make sense anymore since Medicare introduced PLA (Proprietary Laboratory Analyses) codes in 2016,” Richard commented. “These codes certainly don’t make sense for all lab testing because a portion of all testing is routine and straight-forward—meaning there’s no need for additional identifiers.”

UHC Requires PLA Codes

PLA codes are an addition to the AMA’s CPT codes and already include a corresponding descriptor for clinical laboratories that want to identify tests with more specificity. On this point, Polk agreed with Richard. “I have yet to find someone who understands what UnitedHealthcare hopes to accomplish with this program,” she remarked.

“We do know that UHC finally confirmed that all freestanding labs that use place-of-service code 81, and all outpatient hospital laboratories that use POS codes 19 and 22, and that use revenue codes 300 to 319 and 971, are required to register for the test registry protocol,” said Polk. “This information came from a provider relations advocate for UHC.”

Place-of-service 19 is for an off-campus outpatient hospital; 22 is for an on-campus outpatient hospital, and 81 is an independent laboratory.

Along with the need to resolve the confusing aspects of UHC’s test registry program, clinical labs and AP groups have the added administrative burden of registering tests using billing modifiers and the associated number of units, said Polk. “For example, a lab can register an 88305 with 10 units as long as it has never billed for more than 10 units,” she explained. “But should the lab later have a big case of more than 10 units, then UHC will not pay for that claim unless the lab first registered that test with more than 10 units.

List Every Test in a Panel

“In addition, there are numerous clinical lab tests that are ordered as a panel, and labs will need to list each test in those panels,” noted Polk. “Further, when a lab adds a CPT code or when an AP practice adds any new tests, UHC requires that lab or practice to register those tests.

“We tell our clients to compile the test list first before registering that list with UHC,” she continued. “We want to fully understand the registration process before a lab client then registers the tests with UHC, because if a clinical laboratory’s code billed doesn’t match what UHC has in its registry, it will create chaos when claims are submitted.

“We are working with each of our lab and pathology clients to make sure all of their tests get registered correctly with UHC,” she said. “That’s a huge administrative burden for labs, AP groups, and billing companies.”

Contact Leigh Polk at 800-832-5270 x2941 or; Diana Richard at 843-319-2409 or



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