Pathology/Lab Coding Alert

Separate sites on single specimen justify code pair -- and an extra $51

Reporting intraoperative touch preps and frozen sections from the same specimen seemed on the way out -- again -- when the National Correct Coding Initiative (NCCI) bundled 88331 with 88334 in April 2006.

But now our experts indicate that you can recoup $51 for a touch prep during surgery (88334, Pathology consultation during surgery; cytologic examination [e.g., touch prep, squash prep], each additional site) on the same specimen as a frozen section (88331, ... first tissue block, with frozen section[s], single specimen) even though the edit pair remains in effect -- but only under certain conditions.

NCCI Should Limit You -- Not Stop You

When NCCI paired 88331 and 88334, the edit seemed to directly contradict CPT direction about how to use the codes, says Ernest J. Conforti, MSHS, SCT (ASCP) MT, director of anatomic pathology operations at North Shore-Long Island Jewish Health System, headquartered in Great Neck, N.Y.

Problem: NCCI bundles 88331 and 88334 as a column 1/column 2 edit pair, but modifier indicator -1- means you can use modifier 59 (Distinct procedural service) to report the codes together under certain circumstances. Based on common usage of modifier 59, many coders understood the acceptable circumstance to mean separate specimens -- which from a practical standpoint meant that you could never bill 88331 and 88334-59 to Medicare for the same surgical consultation.

Solution: The -specimen- is not really the focus of this edit after all, says Dennis Padget, MBA, CPA, FHFMA, president of DLPadget Enterprises Inc., a pathology business practices publishing company in Simpsonville, Ky. -If the pathologist performs the frozen section and touch prep on different sites of the same specimen, such as the tumor and a separate tumor margin, you can override the 88331-88334 edit using modifier 59,- he says. In other words, the focus of the edit is -site,- not -specimen.-

NCCI Clarifies Edit Pair

In response to a written inquiry regarding the 88331-88334 edit pair, Niles R. Rosen, MD, medical director of NCCI, clarified appropriate conditions to report the two codes together, Padget says. -You can bill for both a frozen section [88331] and touch prep [88334-59] when the pathologist performs the two procedures at separate and distinct sites on the same specimen,- he says.

For instance: The pathologist carries out a frozen section (88331) on the tumor for intraoperative diagnosis and also performs an intraoperative touch prep (88334) at a margin of the resection distinct from the area of the tumor examined by frozen section.

AMA and CAP Instruction Concurs

Documentation from the AMA and the College of American Pathologists (CAP) also confirms that you can report 88331 and 88334 together for different sites on the same specimen
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The AMA clarifies 88331-88334 coding in the March 2006 CPT Assistant: -There may be cases in which both frozen section and intraoperative touch prep analyses are performed. If different analyses are performed on the same specimen but at different sites - it is appropriate to report 88331 and 88334.-

In a presentation for the 2006 CAP annual meeting, Mark S. Synovec, MD, CPT-PCC chair, with Topeka Pathology Group PA in Topeka, Kan., outlined when and how you can report intraoperative frozen sections and touch preps together. Regarding different sites for frozen sections and touch preps on the same specimen, he says, -If - the touch preparation was performed to provide a separate diagnosis (i.e., margin assessment versus tumor classification -), [the frozen section and touch prep] may be coded together.-

You can find the presentation on the Internet at www.cap.org/apps/docs/annual_meeting/cap_06/course_materials/cpt_coding_surgical_pathology_tuesday.pdf.

CPT Describes Frozen Section and Touch Prep During Surgery

CPT added 88333 (Pathology consultation during surgery; cytologic examination [e.g., touch prep, squash prep], initial site) and 88334 in 2006, providing a way to report intraoperative touch preps alone or with intraoperative frozen sections (88331). 

How to do it: CPT provides a text note that instructs you how to code both services: -For intraoperative consultation on a specimen requiring both frozen section and cytologic evaluation, use 88331 and 88334.-

-The CPT instruction clearly states that you can report both 88331 and 88334 for the same specimen when you perform both services,- Conforti says. 

Coding basics: When the pathologist performs a touch prep as part of a surgical consultation, make sure you use 88333 and 88334, not 88161 (Cytopathology, smears, any other source; preparation, screening and interpretation). Reserve 88161 for touch preps that are not part of an intraoperative consult.

Documentation Is Key

To justify 88331 and 88334 charges, you must provide complete and unambiguous documentation. The pathologist must uniquely identify the site subjected to frozen section and each margin as well.

For example: The report might reference the central lesion (frozen section), medial margin (touch prep), proximal margin (touch prep), and deep margin (touch prep). -You have to be able to discern and defend that the pathologist directed each preparation at a distinctly different site on the specimen,- Padget says.