Below is a concise summary of current CMS policy (CY 2025) for laboratory travel allowances and related specimen collection fees, with links to official guidance.

What’s payable

• Specimen collection fee (per encounter, when criteria met)

  • General fee: $9.09 (CY 2025)
  • SNF/HHA add-on: $11.09 (includes $2 PAMA add-on for specimens collected from patients in a SNF or by a lab on behalf of an HHA)
  • Applies when a trained technician personally performs venipuncture or urine catheterization for a homebound patient or a non-hospital inpatient and qualified facility staff aren’t available.
  • Deductible and coinsurance don’t apply to the specimen collection amount for CDLTs.
  • Reference codes CMS cites for collection scenarios: CPT 36415, HCPCS G0471, P9612, P9615.
  • Source: CMS MLN Matters MM13947 (Jan 2025)

• Travel allowance (only when the specimen collection fee is payable)

  • Purpose: Covers transportation and personnel expenses for the technician to travel to the patient location and collect the specimen.
  • Bill one of:
    • P9603: Per-mile travel allowance
    • P9604: Flat-rate travel allowance
  • You may bill a travel allowance per Medicare patient, per location, when collection is needed to perform a CDLT.
  • Do not pay travel for simple pickup/“messenger” services or when collection didn’t require a trained technician.

Choosing per‑mile vs. flat‑rate (P9603 vs. P9604)

• Use P9604 (flat rate) when the round trip to one location is 20 eligible miles or less.
• Use P9603 (per mile) when:
  • The round trip to one location is more than 20 eligible miles, or
  • You travel to more than one location (mileage method applies regardless of distance).
• “Eligible miles” begin at the lab (or technician’s travel start point for collection) and end at the lab (or travel end point).

CY 2025 travel allowance rate and calculations

• Mileage rate: $1.20 per mile (IRS standard mileage $0.70 + personnel component $0.50 based on BLS median phlebotomist wage ÷ 40 mph).
• Proration: Travel allowance amounts must be prorated across the Medicare patients for whom a specimen collection fee applies at that stop/route.
  • CMS specifies not to include non‑Medicare patients in travel allowance calculations.
• How to calculate:
  • P9603 (per-mile): Eligible miles × $1.20 ÷ number of Medicare patients collected on that trip.
  • P9604 (flat rate): ($1.20 × 10) ÷ number of Medicare patients collected at that location (i.e., a fixed 10-mile basis divided among eligible patients).
• Source: CMS MLN Matters MM13947 (Jan 2025)

Place of service (POS) and other billing notes

• Typical POS for travel/collection: home and facility non‑hospital settings (e.g., POS 12 home, 31 nursing facility, etc.). Independent lab POS 81 is not used for the travel allowance line.
• Some MACs publish POS specifics and examples (see Noridian JF Part B).
• Documentation:
  • Maintain electronic documentation of eligible miles (CMS permits electronic records).
  • Homebound indicator requirements apply for independent labs (check MAC instructions).
  • Bill the appropriate collection code with the travel allowance; no travel allowance without a payable specimen collection fee.

Common pitfalls to avoid

• Billing a travel allowance when a specimen was only picked up (no technician-performed collection) — not payable.
• Including non‑Medicare patients in the travel allowance calculation — CMS says do not include them.
• Using flat rate (P9604) when round trip exceeds 20 miles or when multiple locations were visited (use P9603).
• Billing multiple collection fees for multiple tubes or tests in one encounter — only one collection fee per specimen type per encounter.

Primary references

• CMS policy and 2025 rates: CMS MLN Matters MM13947 — Travel Allowance Fees for Specimen Collection (CY 2025)
• MAC example guidance and POS details: Noridian — Specimen Collection and Travel Allowance Fees
  

Note: Commercial payers may differ. Always verify local MAC instructions and payer policies for coding, POS, and documentation requirements.

Abbreviations Used