Pathology/Lab Coding Alert

Specimen-collection date may be wrong.

When you bill the professional component of anatomic pathology (AP) services, you  might need to change the way you report the date of service (DOS).

News flash: Although CMS says this isn’t a “new or revised Medicare policy,” the recent MLN Matters SE17023 sets the DOS for separately-billed AP professional component as “the date the review and interpretation is completed.”

If your practice has been billing these cases using the specimen-collection date as the DOS, you might need to change your ways.

Recognize Affected Cases

The pertinent DOS statement in SE17023 impacts only claims for procedures with a professional component/technical component (PC/TC) indicator of “1” on the Medicare Physician Fee Schedule (MPFS), such as 88302-88309 (Level … - Surgical pathology, gross and microscopic examination …). And then it applies only if you’re billing with modifier 26 (Professional component).

“This situation occurs a lot in our lab, because one of our major hospital clients performs the TC of surgical pathology cases, and our pathologists perform the professional component,” says Judith Watson, chief operating officer with Doctors’ Anatomic Pathology Services in Jonesboro, Ark.

Lacking prior specific instruction to the contrary, many labs currently use the specimen-collection date for professional-component billing, to be consistent with their policy for global or technical-component billing.

No change? Regarding the professional service DOS, SE17023 refers to the Medicare Benefit Policy Manual Chapter 15 Section 20, which defines the DOS as the “date the beneficiary received the service.” In section 20.1, which describes billing all surgical-package care using the date of surgery, the manual describes an exception: “Expenses for services rendered by other physicians are considered incurred on the date they were performed.” These statements may be the basis of CMS’ claim that SE17023 does not describe any new or revised policy.

See How Policy Might Affect You

Labs that bill only the professional component for some histology cases might need to change how they file their claims.

For example: The hospital histology lab prepares paraffin-embedded slides from a needle liver biopsy on April 2, 2019 and sends the slides to the pathologist in your practice who interprets and reports on the slides on April 5, 2019. The hospital lab reports 88307-TC (Level V - Surgical pathology, gross and microscopic examination … Liver, biopsy - needle/wedge … Technical component) with a DOS of April 2. The pathologist bills 88307-26, with a DOS of April 5 on Form CMS-1500 item 24A, in accordance with SE17023 guidance.

Problem: “Different dates of service on separate bills for the technical and professional components of a single service could create confusion,” warns William Dettwyler, MT AMT, president of Codus Medicus, a laboratory coding consulting firm in Salem, Ore.

“Using 2 different dates for TC and 26 might make it more difficult for payers to match the components and make sure they’re not being double billed, and that they’re not double paying,” Dettwyler says. Also, patients may question coverage determinations for a service on a date that they did not have a medical encounter, and labs may have trouble coding or tracking services involving a single specimen that occurs on separate dates.

For instance: “If our pathologist evaluates three distinct immunostains on a specimen on a single date, and a fourth immunostain on the same specimen as an addendum three days later, we would report all the stains using the specimen-collection date. That means we would bill 88342-26 (Immunohistochemistry or immunocytochemistry, per specimen; initial single antibody stain procedure) for the first stain, and three units of +88341-26 (… each additional single antibody stain procedure (List separately in addition to code for primary procedure)),” Watson says. “But if the addendum is billed on a different date of service, should we bill that fourth stain as 88342-26?”

Bottom line: The DOS change in SE17023 could result in some unexpected complications. Review your current policy, and contact your Medicare Administrative Contractors (MACs) before fully implementing this change.

Don’t Apply Rule to Global or TC Bills

Billing codes 88302-88309 for the global service (with no modifier), or for only the technical service (with modifier TC [Technical component]) requires no change to reporting your claims’ DOS. You should continue to bill those cases using the specimen-collection date for the DOS.

Special cases: If the pathologist performs only the professional component, but bills a global fee after purchasing the technical component from an independent lab or hospital lab, you should adhere to the global-billing rule and assign the DOS as the specimen-collection date.

SE17023 weighs in: When billing a global service, the MLN Matters article allows providers to “submit the professional component with a date of service reflecting when the review and interpretation is complete.” But the article also specifically allows continued global-billing using the specimen-collection date by stating, “When billing a global service, the provider can submit … the date of service as the date the technical component was performed.”

Grasp ‘Archived’ and ‘14-Day Rule’ Exceptions

If the pathologist performs a service on an archived specimen – stored more than 30 days – there’s no change to the DOS policy. You should report the DOS as the date the specimen comes from storage.

There’s also no change to the “14-Day Rule,” which states that you must report the date the pathologist performs the service when you meet the following criteria:

• The physician orders the medically-necessary service at least 14 days after the patient’s hospital discharge
• The physician collected the specimen during a hospital surgical procedure (and it would have been medically inappropriate to do otherwise)
• The pathologist’s results don’t guide treatment during the hospital stay.