Pathology/Lab Coding Alert

A breakthrough bone marrow code has vanished before our very eyes. Promising a new G code for Bone marrow aspiration and biopsy performed on the same day, CMS reneged on the deal in the Final Rule for the 2003 Physician Fee Schedule.

CMS has long held that you cannot bill for both a bone marrow aspiration (38220, Bone marrow; aspiration only) and biopsy (38221, ... biopsy, needle or trocar) performed through the same incision. When they are performed together, Medicare will pay only for the most extensive procedure (38221). A new HCPCS Level II code in the June 28, 2002, proposed 2003 Physician Fee Schedule would have changed all that, however, providing a single, new code for both services.

"Then came CMS'withdrawal of the proposed G code in the final rule, and we're right back where we started," says Dennis Padget, CPA, FHFMA, president of Padget & Associates, a pathology financial and compliance consulting firm in Simpsonville, Ky.

"Not creating this code may be a blessing in disguise," Padget says. The June 28 proposed payment rate for the combined service code paid only 13 percent more than the bone marrow biopsy alone not a good deal for pathologists. "Medicare's traditional formula paying the full value of the more extensive procedure, plus 50 percent of the lesser service would pay 39 percent more for the concurrent procedures than 38221 alone," Padget says.

Withdrawal of the G-code proposal does not change correct coding for bone marrow procurement services from different anatomic sites (for example, aspiration from bilateral iliac crests). Pathologists should report such an occurrence with two units of 38220 using modifier -59 (Distinct procedural service) to indicate that the codes represent two body sites or patient encounters.

"CMS stated in the Final Rule that it will submit a proposal to the AMA for bone marrow biopsy and aspiration through the same incision in time for CPT 2004, and that is good news," Padget says. "In the meantime, continue to bill Medicare only for the more extensive procedure and follow other payers' rules accordingly."