Pathology/Lab Coding Alert

CMS still promises path/lab instruction.

The place of service (POS) implementation deadline is upon us (April 1, 2013), yet, as of press time, CMS hasn’t produced the much-promised clarification for pathology.

Back story: On March 29, 2012, Medicare issued Transmittal 2435 (Change Request [CR] 7631) for new POS rules, which included this statement: “Clarification on the POS for pathology services will be provided through another CR.” Through multiple CMS Transmittal updates (2561 on Sept. 28, 2012; 2563 on Oct. 11, 2012; and 2613 on Dec. 14, 2012), the promise of a clarification for pathology remains — unfulfilled.

Don’t be Fooled

Some Medicare contractors may be telling you that CR7631 is the only instruction that labs have, despite the confusing nature of the instruction for pathology and laboratory services.

“At a mid-March Webinar on POS implementation, our Medicare contractor stated that they are ‘not aware of any clarification other than the CR 7631’ forthcoming for labs,” reports Judith Watson, accounts receivable manager with Doctors’ Anatomic Pathology Services in Jonesboro, Ark.

Hold on: “But according to my conversation with a representative at the College of American Pathologists (CAP), CMS stated that the April 1 deadline ‘does not extend to pathology and labs,’ and the agency is planning a call with Medicare contractors around April 11 to advise them that POS for path/lab should remain the same until the new CR is issued,” Watson says.

Confirmed: CMS issued Transmittal 2679 on March 29, stating, “Transmittal 2613, dated December 14, 2012, is being rescinded and replaced by Transmittal 2679, to indicate that clarification on the place of service for pathology and laboratory services will be provided through another Change Request.”

Caution: Transmittal 2679 still contains the same language for independent labs — “If an independent lab bills, the place where the sample was taken is shown [as the POS]. An independent laboratory taking a sample in its laboratory shows ‘81’ as place of service. If an independent laboratory bills for a test on a sample drawn on an inpatient or outpatient of a hospital, it uses the code for the inpatient (POS code 21) or outpatient hospital (POS code 22), respectively.”

“Based on that specific language, I don’t see CMS coming out with anything in the anticipated ‘pathology-specific’ transmittal that would change the fundamental instructions set forth in those three sentences,” says Dennis Padget, MBA, CPA, FHFMA, president of DLPadget Enterprises Inc. and publisher of the Pathology Service Coding Handbook, in The Villages, Fla.

Understand the Problem

The CMS national rule outlined in CR 7631 uses “face to face service” location as the primary factor in choosing your POS code.

Under the rule, “providers performing the PC [professional component] of interpretation of tests must use the POS where the face-to-face service ... was performed, [such as] outpatient facility, ASC [ambulatory surgical center], etc.,” says Catherine Brink, BS, CMM, CPC, CMSCS, president of NJ-based Healthcare Resource Management.

But because pathologists rarely perform “face to face” service and often do tissue or cytology exams at a site other than the patient location, the instruction is confusing for pathologists.

Resource: To see the latest instruction — Transmittal 2679 — head to www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R2679CP.pdf.