Within the hospital-based laboratory, phlebotomy services are tightly defined. Phlebotomy is provided in select locations — in patient care units and rooms, outpatient office locations, and designated patient service centers. Many outreach programs also serve skilled nursing or assisted living facilities, support home healthcare programs, and even perform phlebotomy for home-bound patients. 

As the phlebotomist ventures farther from the hospital or formal outpatient setting, there are many new facets to consider. Remote phlebotomy is a patient-focused activity and can be a successful attribute for an outreach program when deployed and supported effectively. To realize success, it is important to consider the following:

Define service and parameters.

A critical first step is to establish a definition of the types of patients that the laboratory will serve through an off-site phlebotomy program. Skilled nursing facility patients require frequent laboratory tests, and a laboratory can usually justify providing phlebotomy services several times per week. Assisted living facility patients are generally in better health and do not require testing as frequently. Home-bound patient needs may vary, depending on their medical condition.

When supporting off-site phlebotomy, it is important to not try to be everything to everyone. Define parameters such as distance, hours of service, minimum or maximum numbers of patients in a location, and patient qualification criteria.

Establish patient qualification criteria.

Patients in skilled nursing or assisted living facilities have demonstrated mobility limitations and require phlebotomy support in their place of residence. Patients who are home-bound may have similar limitations. Defining whether the homebound service is one of medical necessity, versus convenience, is an essential first step.

The Centers for Medicare and Medicaid Services (CMS) has a specific definition for a homebound patient, which states [sic] that the patient has a condition such that leaving his or her home is medically contraindicated, and there is a normal inability to leave home.[i] If the provider has determined that a patient meets the CMS definition, then in-home phlebotomy is warranted. If the laboratory has the capability of dispatching a phlebotomist to a patient’s home, this patient-centered service can be a true satisfier and differentiator in a market. For patients who do not meet the CMS-defined criteria, and if the laboratory has capacity to support the requests, it may be an opportunity to provide a concierge service that collects a cash payment directly from the patient.

Equip the phlebotomist for off-site work.

A remote phlebotomist must demonstrate a level of competence or proficiency and may require additional training before being allowed to perform off-site phlebotomy. They will require routine, as well as special-need specimen collection supplies, and backup supplies in case of a difficult venipuncture. Provide adequate biohazard bags, temperature stabilization materials, and transportation containers to ensure specimen stability during transit. If there will be a delay in transporting the specimen to the laboratory, consider providing a portable centrifuge that can be used in the phlebotomist’s vehicle. Ensure phlebotomist safety by providing a biohazard sharps container and a spill kit in the vehicle.

Establish processes and policies that enable success.

Any remote phlebotomy program will be more successful when the phlebotomists are able to plan and manage their workload. Requiring a list of skilled nursing or assisted living facility patients in advance will ensure that the laboratory is providing adequate staff to meet facility needs. Scheduling home-draw patients will ensure that the patient is ready for the procedure at the correct time. Consider phlebotomist safety and establish policies accordingly, such as asking the homebound patient to secure any pets in a separate room before the phlebotomist enters the home.

Document phlebotomist activities for accurate billing.

In order to correctly bill for the CMS Travel Allowance,[i] it is necessary to accurately document miles driven to the remote phlebotomy patients. Provide a mileage and activity log for the phlebotomist so they can document miles driven, procedure, patient, and date and time of collection. Log all mileage and allocate trip mileage accordingly.

For an outreach program, providing remote phlebotomy services is highly patient-focused and can help differentiate a laboratory from its competitors. Effective program management, staff training, and support will ensure the program’s success.

[i] www.cms.gov/files/document/mm13071-travel-allowance-fees-specimen-collection-2023-updates.pdf

[i] www.cms.gov/regulations-and-guidance/guidance/transmittals/2017downloads/r704pi.pdf