Pathology/Lab Coding Alert

Confirm FNA Unit of Service for Medicare

Lesion and evaluation episode constrain coding.

If you understand how to report your pathologists' fine needle aspiration (FNA) adequacy check and cytologic diagnosis based on CPT® instruction, you won't have a problem with CMS's addition to the NCCI Policy Manual regarding FNA.

That's because the policy manual update for the following codes comports directly with CPT® guidance:

  • 88172 -- Cytopathology, evaluation of FNA; immediate cytohistologic study to determine adequacy for diagnosis, first evaluation episode, each site
  • 88177 -- ... each separate additional evaluation episode, same site (List separately in addition to code for primary procedure).

"The manual confirms that the approved unit of service for FNA immediate study code 88172 is the initial evaluation episode per each different lesion (anatomic site)," says Dennis Padget, MBA, CPA, FHFMA, president of DLPadget Enterprises Inc. and publisher of the Pathology Service Coding Handbook, in The Villages, Fla.. "If additional episodes are necessary for a lesion, each additional evaluation episode is properly reported with code 88177."

Forget 'pass': "An evaluation episode is not the same thing as a 'pass,'" Padget warns. Rather, an evaluation episode involves the pathologist's exam and report to the surgeon regarding the adequacy for diagnosis of a set of cytologic material, regardless of the number of passes the surgeon performed to extract the material.

The NCCI Policy Manual clarifies this issue by stating that "an additional evaluation episode [88177]... cannot begin before an assessment is rendered by the pathologist to the operating physician, and the operating physician uses the assessment to determine whether additional needle passes should be performed."

Start over for new lesion: If the operating physician performs one or more passes on a second lesion at a different anatomic site and submits the cytologic material to the pathologist for an adequacy check, report a second unit of 88172.

The policy manual clarifies this point by stating, "CPT code 88172 may be reported with one UOS [unit of service] for each separate lesion evaluated."

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