Pathology/Lab Coding Alert

Beware CLIA-waived confusion.

If your lab performs drug testing, you might already be using some new CPT^® codes in place of other deleted CPT^® and HCPCS Level II Codes. But you just might be running into problems; we’ve heard reports of trouble from lab managers and coders like you.

Read on to get a firm grip on what codes have changed, and how and when you can expect to use the new arrangement to get paid for your work.

No Question — Delete 5 CPT® Drug Screen Codes

This much is clear: CPT^® deletes the following codes effective Jan. 1, so you should no longer be billing these codes:

• 80300 — Drug screen, any number of drug classes from Drug Class List A; any number of non-TLC devices or procedures, (e.g., immunoassay) capable of being read by direct optical observation, including instrumented-assisted when performed (e.g., dipsticks, cups, cards, cartridges), per date of service
• 80301 — … single drug class method, by instrumented test systems (e.g., discrete multichannel chemistry analyzers utilizing immunoassay or enzyme assay), per date of service
• 80302 — Drug screen, presumptive, single drug class from Drug Class List B, by immunoassay (e.g., ELISA) or non-TLC chromatography without mass spectrometry (e.g., GC, HPLC), each procedure
• 80303 — Drug screen, any number of drug classes, presumptive, single or multiple drug class method; thin layer chromatography procedure(s) (TLC) (e.g., acid, neutral, alkaloid plate), per date of service
• 80304 — … not otherwise specified presumptive procedure (e.g., TOF, MALDI, LDTD, DESI, DART), each procedure.

Look back: Prior to 2017, you had to bill presumptive drug tests differently to Medicare, using three HCPCS level II codes. But now CMS deletes those codes for 2017 too, as follows:

• G0477 — Drug test(s), presumptive, any number of drug classes; any number of devices or procedures, (e.g. immunoassay) capable of being read by direct optical observation only (e.g., dipsticks, cups, cards, cartridges), including sample validation when performed, per date of service
• G0478 — … any number of devices or procedures (e.g. Immunoassay) read by instrument-assisted direct optical observation (e.g., dipsticks, cups, cards, cartridges), including sample validation when performed, per date of service
• G0479 — … any number of devices or procedures by instrumented chemistry analyzers (e.g. immunoassay, enzyme assay, TOV, MALDI, LDTD, DESI, DART, GHPC, GC mass spectrometry), includes sample validation when performed, per date of service.

Confusion Reigns — Replace G0477-G0479 with 80305-80307

In addition to deleting 80300-80304, CPT^® 2017 adds the following codes:

• 80305 — Drug test(s), presumptive, any number of drug classes, any number of devices or procedures (e.g., immunoassay); capable of being read by direct optical observation only (e.g., dipsticks, cups, cards, cartridges) includes sample validation when performed, per date of service
• 80306 — … read by instrument assisted direct optical observation (e.g., dipsticks, cups, cards, cartridges), includes sample validation when performed, per date of service
• 80307 — Drug test(s), presumptive, any number of drug classes, any number of devices or procedures, by instrument chemistry analyzers (e.g., utilizing immunoassay [e.g., EIA, ELISA, EMIT, FPIA, IA, KIMS, RIA]), chromatography (e.g., GC, HPLC), and mass spectrometry either with or without chromatography, (e.g., DART, DESI, GC-MS, GC-MS/MS, LC-MS, LC-MS/MS, LDTD, MALDI, TOF) includes sample validation when performed, per date of service.

The three new codes are essentially the same as the “G” codes G0477-G0479, with a few very minor editorial changes, noted Paul W. Radensky, M.D. J.D., principal, McDermottPlus Consulting in his address at the Clinical Laboratory Fee Schedule (CLFS) annual public meeting last year.

The changes in wording primarily add clarity without changing how you’d use the codes, for instance, expounding that some of the method examples are a type of mass spectrometry either with or without chromatography.

CMS decision: In the payment final determination following the public meeting, CMS stated that the agency would “crosswalk CPT^® code 80305 to code G0477, then delete G0477; crosswalk CPT^® code 80306 to code G0478, then delete G0478; and crosswalk CPT^® code 80307 to code G0479, then delete G0479.” The CLFS affirms thisdecision by listing a payment amount for 80305-80307, while not includingG0477-G0479 in the file. You can find documentation of these changes at www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/ClinicalLabFeeSched/Downloads/CY2017-CLFS-Codes-Final-Determinations.pdf and www.cms.gov/apps/ama/license.asp?file=/Medicare/Medicare-Fee-for-Service-Payment/ClinicalLabFeeSched/Downloads/17CLAB.zip.

Problem: Some Medicare payers are still instructing labs to use a ‘G’ code. For instance, Noridian Part B Jurisdiction F reportedly instructed practices earlier this year to continue to use G0477-QW (CLIA-waived test) for the appropriate drug screen devices.

In fact, the list of waived tests effective Jan. 1, 2017 under the Clinical Laboratory Improvement Amendments (CLIA) lists G0477-QW, but not 80305 (www.cms.gov/Regulations-and-Guidance/Legislation/CLIA/Downloads/waivetbl.pdf).

Resolve discrepancy: To clear up the confusion on this point, CMS issued MLN Matters MM9956 on Jan. 20 (www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9956.pdf). The memo states, on page 4, “The HCPCS code G0477 was discontinued on 12/31/2016. The new HCPCS code 80305 was effective 1/1/2017. HCPCS code 80305QW describes the waived testing previously assigned the code G0477QW. All tests in the attachment that previously had HCPCS G0477QW are now assigned 80305QW.”

Because the effective and implementation dates of this MM9956 are April 1 and April 3, respectively, your MAC may not apply the change until then. Look for instruction from your local provider about how to handle this. For instance, some MACs have issued instructions to report the 80305QW instead of G0477QW, but to hold relevant claims until the change is effective in April.

Payment impact: As you move to using 80305-80307 instead of G0477-G0479, you can expect your pay to hold steady. That’s because the code descriptors and resources are essentially similar, as noted by Ronald McLawhon, MD, PhD, representing the College of American Pathologists at the annual CLFS public meeting last year, so CMS crosswalked the G codes to the new CPT^® codes for 2017.