Third-party billing for an Embyo Transfer on a Gestational Carrier

The IP’s insurance plan has coverage for embryo transfer. Upon further clarification with the insurance plan, the IP has confirmed that the plan will cover not only the embryology codes, but also the codes which are performed to the GC, including ultrasound during transfer and embryo transfer. The plan representative is advising that the ultrasound and embryo transfer codes should be billed with the IP’s name on the claim, not the GC’s, stating that this is an acceptable practice so long as there is a coding modifier attached to demonstrate the embryo transfer was done on a GC.

Is it considered compliant to send out a claim to insurance for embryo transfer with the IP’s name as the person who the service was rendered to when the service was actually rendered to the GC, so long as the correct modifier is attached? If yes, what diagnosis code and what modifier would you attach to the embryo transfer cycle CPT codes?