Pathology/Lab Coding Alert

You can still report separate cytopathology

You shouldn't be reporting the CPT 88160 family for cytopathology smears with surgical pathology codes (88304-88309), according to Medicare's new National Correct Coding Initiative (NCCI) edits. Now that the edits are in effect (Oct. 1), you'll have to override these edit pairs when you perform both services on different sources.

Surgical Pathology Includes Slide Interpretation

By stating that 88160-88162 (Cytopathology, smears, any other source; ...) are components of 88304-88309 (Surgical pathology, gross and microscopic examination ...), CMS indicates that cytopathology smears prepared from surgical pathology specimens represent duplicate procedures. But what should you do when the pathologist performs an 88304-88309 service on a tissue specimen and an 88160-88162 service on a different sample source for the same patient on the same day?

Use Modifier -59 to Override the Edit Pair

Because of the new NCCI edit pairs, you'll have to append modifier -59 (Distinct procedural service) when you perform these surgical pathology and cytopathology services on different sources for the same patient on the same day.
 
"Performing a surgical pathology and cytopathology interpretation the same day would not be that unusual," says Ernest J. Conforti, MSHS, SCT (ASCP) MT, DLM, assistant director/chief of anatomic pathology at North Shore University Hospital in Manhasset, N.Y. Such cases might include the pathologist performing "touch preps" during surgery before examining the excised tissue, or examining sputum and lung tissue pathology for the same patient on the same day.
 
For instance, if a surgeon performs a breast lesion lumpectomy and requests the pathologist's intraoperative touch-prep evaluation of four margins individually identified by orientation, "you should report a surgical pathology code for the lumpectomy exam, and a cytopathology code for each of the touch-prep margin exams," Conforti says. "You should also report one unit of 88329 (Pathology consultation during surgery) for the intraoperative consult."
 
Report the breast lesion exam as 88307 (Level V - surgical pathology, gross and microscopic examination, breast, excision of lesion, requiring microscopic evaluation of surgical margins). Use 88161 (Cytopathology, smears, any other source; preparation, screening and interpretation) to report each touch prep, which involves crushing or touching excised tissue to a slide to remove cells for tumor evaluation. Append modifier -59 (Distinct procedural service) to 88161, indicating that it is a separate service on a different source, not a description of the 88307 tissue slide evaluation. You should identify the source of each cytology exam, such as "breast lesion touch prep, margin quadrant one."
 
"Good documentation should include a specific description of the source, so the pathologist should not simply state 'other,' even though the code definition uses that word," Conforti says. "Ideally, the pathology report also shows a diagnosis for each of the four touch preps and a diagnosis for the breast lesion." By identifying each separate service and diagnosis, the documentation supports separately billing each cytopathology and surgical pathology procedure.

'Other Source' Is Not Gynecology or Fluids

If you understand the proper use of the 88160 family, there's no need to bundle these codes with surgical pathology codes 88304-88309 as CMS has done. "For the 88160 cytopathology codes, 'other source' doesn't refer to just any source, such as tissue. It refers to any cell source besides those described by the other cytopathology codes: that is, other than cervical/vaginal or fluids/washings/ brushings," says Kenneth Wolfgang, MT (ASCP), CPC, CPC-H, director of coding and analysis for National Health Systems Inc., a coding consultation company in Camp Hill, Pa. "Other than touch preps for 88161, about the only sources that fit in this category are smears from sputum or nipple discharge, which you should report as 88160 or 88162 for more than five slides."

Watch Out for 88180

NCCI 9.3 also bundles 88180 (Flow cytometry; each cell surface, cytoplasmic or nuclear marker) with the
88160 family, and with 88108 (Cytopathology, concentration technique, smears and interpretation [e.g., Saccomanno technique]). As with the surgical pathology bundles, these new edit pairs mean that you must use modifier -59 if your lab performs flow cytometry and a cytopathology evaluation (88108 or 88160-88162) on two different sources for the same patient on the same day.
 
For example, labs may perform flow cytometry to rule out lymphoma when a high lymphoid population is present on a concentrated fluid smear. In that case, you'll have to override the new NCCI edit pair. "If the lab performs both the concentrated fluid smear exam and the flow cytometry, you should report 88180 and 88108-59 to indicate that you performed two distinct services,"  Conforti says.