Pathology/Lab Coding Alert

Agency denies reconsideration request.

Your lab will continue to get the same pay for a dipstick or chemistry analyzer screening for multiple drug classes in a single patient encounter.

That's according to the agency's preliminary payment determination, in which CMS denied industry commentators' requests at the annual laboratory public meeting to distinguish the services.

Keep With Current Practice

When your lab performs a drug screen for a Medicare beneficiary, you should code the work as one unit of G0434 (Drug screen, other than chromatographic; any number of drug classes, by CLIA waived test or moderate complexity test, per patient encounter) when the lab uses any of the following methods:

• CLIA waived or non-instrumented moderate complexity test systems read by direct optical observation (such as dipsticks, cups, or cards)
• Moderate complexity instrumented test systems intended for repeated use, not read by direct optical observation (such as spectrophotometers, multi-channel chemistry analyzers, and fluorometers).

Don't Expect Additional Code

Several commentators at the Clinical Laboratory Fee Schedule (CLFS) annual public meeting suggested changing G0434 to include only CLIA waived and non-instrumented moderate complexity tests, while introducing a new code for moderate complexity instrumented tests with pricing at four times G0434.

The current grouping under G0434 penalizes clinical labs that perform these tests using instrumented moderate complexity systems, according to Paul Radensky, representing McDermott Will & Emery LLP at the CMS public meeting. The moderate complexity instruments provide some clinical advantages, such as higher specificity, that commentators said should not be discouraged by coding and reimbursement.

CMS says no: The agency's preliminary crosswalk decision is to "retain the same descriptor and payment" and not create an additional G code. CMS' rationale for the decision made the following points:

• cost data did not justify higher payment for instrumented moderate complexity systems
• moderate complexity instruments are used to perform other tests, such as cardiac disease testing
• some commentators supported the reasonableness of current reimbursement.

To read more about the decision, visit http//: www.cms.gov/ClinicalLabFeeSched/Downloads/CY2012_Preliminary_Rationale-Web-Posting-Document.pdf