Pathology/Lab Coding Alert

You'll still need physician for professional component.

You can't report 88367-88368 (Morphometric analysis, in situ hybridization (quantitative or semiquantitative), each probe) if a PhD results the test instead of a physician interpretation. Should you expect the same restriction if you're using the new codes for urinary tract specimens (88120-88121, Cytopathology, in situ hybridization (e.g., FISH), urinary tract specimen with morphometric analysis, 3-5 molecular probes, each specimen)?

"Medicare law doesn't recognize doctorate level professionals (PhD) for professional component payment," says Dennis Padget, MBA, CPA, FHFMA, president of DLPadget Enterprises Inc. and publisher of the Pathology Service Coding Handbook, in The Villages, Fla. "Medicare law isn't affected by state certification standards for PhDs -- test results by a laboratory PhD alone aren't payable under Medicare Part B...period."

Review CMS 88367-88368 Restriction

Don't expect to report 88367 or 88368 to Medicare if a PhD alone performs the professional component. CMS states the following in the Correct Coding Initiative (CCI) Policy Manual:

"The physician ... work component of 88365-88368 requires that a physician (limited to M.D./D.O.) rather than laboratory scientist or technician read, quantitate (88367,88368), and interpret the tissues/cells stained with the probe(s). If this work is performed by a laboratory scientist or technician, CPT codes 88271-88275 should be reported."

Focus on physician work: According to the AMA in CPT Changes 2005: An Insider's View, the physician's work for 88367-88368 involves "determining the appropriate areas of the tumor to evaluate, followed by interpretation of the FISH quantifying amplification..."

Don't miss: You can't simply report the 88367 or 88368 technical component (TC) if a PhD results the test. According to the CCI policy manual, you need the physician's input "to obtain a reportable probe result," so you can't use the codes at all without a physician.

Apply Same Logic to 88120-88121

CPT Changes 2011: An Insider's View ascribes similar "physician work" duties to 88120-88121, as follows:

• Assess background inflammatory and squamous epithelial cells
• Select representative cells for digital fluorescence micrograph
• Evaluate hybridization preparation
• Prepare a report based on micrograph and probe signal counts.

CMS assigns a TC and professional component (26) to 88120 and 88121. Applying the same logic that CMS uses for 88367 and 88368, you should not use new codes 88120-88121 if a PhD alone results the test without a pathologist's involvement.

Do this: For urinary tract specimen FISH testing performed without a physician, you should continue to report the test using the applicable codes (and units) from the 88271-88275 series.