Pathology/Lab Coding Alert

Just because Medicare's Correct Coding Initiative (CCI) edits bundle lots of procedures with fine needle aspirations (FNAs), that shouldn't stop you from reporting all the services you-re entitled to bill.

Here's when you can legitimately override these edits to bring in all the pay you deserve.

Scoop: CPT provides two codes for FNA evaluation:

- 88172 -- Cytopathology, evaluation of fine needle aspirate; immediate cytohistologic study to determine adequacy of specimen(s)

- 88173 -- - interpretation and report.

These codes represent separate and distinct services that a pathologist might perform for a single FNA specimen.

-You should use the codes together when your pathologist performs both the immediate adequacy check and the interpretation,- says William Dettwyler, MTAMT, president of Codus Medicus, a coding consulting firm in Salem, Ore.

Pathologists sometimes evaluate FNA specimens intraoperatively so the surgeon can use the findings to determine the need for additional aspirations from the same lesion, or for a more complex procedure like a needle-core biopsy. That doesn't mean you should report an intraoperative consult using codes from the 88329 (Pathology consultation during surgery) family.

Pitfall: You should always report the most specific codes to describe the FNA evaluation(s) -- 88172 and/or 88173 -- regardless of when or where the procedure occurs relative to surgery. And you should not bill for an intraoperative consult in addition to 88172 and 88173, because the FNA codes include evaluating slides and communicating results.

Look at the edits: In fact, CCI bundles 88172 and 88173 with 88329 (Pathology consultation during surgery), 88333 (- cytologic examination [e.g., touch prep, squash prep], initial site), and 88334 (- cytologic examination [e.g., touch prep, squash prep], each additional site), as you can see on the table on page 37.

Let the codebook speak: Just to make sure you-re not confused about intraoperataive consultations- relationship to FNA cytology evaluation, CPT places this note under 88334: -Do not report 88333 and 88334 for intraprocedural cytologic evaluation of fine needle aspirate, see 88172.-

On the other hand, you might need to report the FNA and intraoperative consultation codes together in some cases.

-It's conceivable you-d have the pathologist evaluate an FNA and an intraoperative touch prep from a percutaneous needle biopsy for the same patient on the same day,- says Dennis Padget, MBA, CPA, FHFMA, president of DLPadget Enterprises Inc. in The Villages, Fla., and publisher of Pathology Service Coding Handbook.

Do this: To report the FNA and intraoperative consultation codes together when you have distinct specimens, you should override the CCI edit pair by appending modifier 59 (Distinct procedural service) to the column 2 code. For the above example, you-d report 88173 for the FNA (assuming no immediate study), 88333-59 for the intraoperative touch prep, and 88305 for the tissue biopsy, according to Padget.

-Note that clear and complete medical reporting is absolutely crucial to proper coding and audit support for these cases,- Padget warns.

Based on specimen source and slide preparation method, CPT provides eight specific codes for non-gyn cytology other than FNA, as follows:

- 88104 --  Cytopathology, fluids, washings or brushings, except cervical or vaginal; smears with interpretation

- 88106 -- - simple filter method with interpretation

- 88107 -- - smears and simple filter preparation with interpretation

- 88108 --Cytopathology, concentration technique, smears and interpretation (e.g., Saccomanno technique)

- 88112 -- Cytopathology, selective cellular enhancement technique with interpretation (e.g., liquid based slide preparation method), except cervical or vaginal

- 88160 -- Cytopathology, smears, any other source; screening and interpretation

- 88161--- preparation, screening and interpretation

- 88162 -- ... extended study involving over 5 slides and/or multiple stains.

Pitfall: Don't report these codes instead of, or in addition to, 88172 or 88173 for an FNA specimen. Forexample, if you get a fine needle aspirate specimen in a vial from a physician clinic and prepare it as cytospin smears, report the most specific code -- 88173 -- instead of 88108.

Reason 1: An FNA specimen is a source distinct from -fluids, washings or brushings- (88104-88107), concentrated or liquid-based smears (88108-88112), and -any other source- (88160-88162). -Only 88172 and 88173 describe the FNA specimen type,- Dettwyler says.

Reason 2: -Medicare considers a second preparation on a specimen to be a -duplicate- service, except when the second preparation is a tissue cell block,- Padget explains.

-Although conventional wisdom says that when a pathologist orders both direct smears and concentrated/ cellular enhanced smears to properly evaluate an FNA you should be able to report both methods, the CCI edits say you can't report 88108 or 88112 together with 88173 for the same specimen.-

See the limits: Study the edit pairs in the table to see how CCI bundles non-gyn cytology with FNA.

Watch for override opportunity: If you have separate specimens, such as a bronchial brushing (88104) or pleural fluid cytospin (88108) taken the same day as a lung FNA specimen (88172 and/or 88173), you can override the CCI edits using modifier 59 on the column 2 code, according to Padget.

Pathologists often review FNA cases as part of a consultation on material referred from another lab. You should properly report those services using one of the following outside consult codes based on the case circumstances: