Oncology & Hematology Coding Alert

Bone Marrow Biopsy and Aspiration Revisited - How to Unbundle 38220, 38221 for Better Pay

The advice youve read and heard about coding bone marrow aspirations and biopsies could be wrong and costing your practice deserved dollars.
 
If your oncologist performs 38220 (Bone marrow; aspiration only) and a 38221 ( biopsy, needle or trocar) on the same date of service for the same patient, you should report only the biopsy, unless your physician performed two different incisions. Thats because the National Correct Coding Initiative ( NCCI Edits ) bundles 38220 and 38221 and allows for unbundling only on the condition that the procedures occur through separate incisions or during different patient encounters.
 
You can separately report 38220 and 38221 if the physician performs two different punctures (meaning the aspiration and biopsy involve two different bone marrow sites) even if the physician goes through only one incision, says Martin Neltner, president of Neltner Billing & Consulting in Independence, Ky.
 
Also, the American Medical Association added the word only to this years descriptor of 38220, so you should use this code only when your oncologist documents that small pieces of bone were aspirated with a needle or trocar, says Linda L. Lively, MHA, CCS-P, RCC, CHBME, founder and CEO of American Medical Accounting and Consulting in Marietta, Ga. Report 38221 to describe the marrow aspiration, she says.

Report 2 Punctures (2 Sites) as 2 Procedures

When you report biopsy and aspiration separately to Medicare or private carriers, report 38221 first because CMS places a greater value on that code, Lively says. Most local carriers havent published definitive guidelines regarding 38220 and 38221, so bill the procedures separately until your carrier rejects them or creates guidelines, she says.
 
If Medicare or your local carrier rejects your claims, use modifier -59 (Distinct procedural service). According to NCCI, you can separately report these codes using modifier -59 only if your physician performed two separate and distinct procedures, says Jan Beach, CMM, CPC, LHRM, administrator of Hematology-Oncology Practice in Vero Beach, Fla.
 
Distinct procedures for 38220 and 38221 involve two separate access sites (punctures), she says. In other words, if the physician goes into two different sites of the bone marrow and retrieves two different specimens (aspiration and biopsy), you should report these procedures separately, regardless of whether your physician performs them through the same incision or two.

Follow These Steps to Justify Unbundling

Your physicians documentation of the procedures technique is the key to unbundling these procedures and getting paid, Neltner says. Your physicians dictation must note that the aspiration and biopsies occurred in different sections of the bone marrow, through different withdrawal accesses (different punctures), for example by stating, I did the incision. I took the needle, went into the marrow, pulled out the aspirate, I came back out, I moved over two centimeters, put back in a needle and took out a biopsy, he says.
 
Also, request that your oncologist take the following steps when he or she documents the procedures, which will help justify your unbundling of 38220 and 38221:
 
 Explain the reasons for entering through two separate sites but (if appropriate) using only one incision. Bone marrow biopsies and aspirations often involve one incision and two separate punctures. Oncologists dont uniformly perform two incisions, says Cary Presant, MD, FACP, professor of clinical medicine at the University of Southern California School of Medicine, president of the Medical Oncology Association of Southern California and president of California Cancer Medical Center, so read your physicians notes.
 
 Describe the different specimens obtained in an aspiration or biopsy, which will highlight the procedures as separate, Presant says.
 
 List the tools used. For example, bone marrow biopsy and aspiration procedures normally involve different needles. Therefore, the two needles are part of the procedure that is best for procuring adequate samples, among other details, Presant says.
 
 Both the bone marrow aspiration and biopsy procedures serve two different diagnostic purposes. For example, the information obtained from an aspirate can point in a different diagnostic direction than that from a core biopsy, says Dennis Padget, CPA, FHFMA, president of Padget & Associates, a pathology financial and compliance consulting firm in Simpsonville, Ky.

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