Pathology/Lab Coding Alert

Question: Can we bill 88104 and 88108 together for the same non-gyn cytology specimen if the lab prepares and the pathologist diagnoses both direct and concentrated smears?

Maryland Subscriber

Answer: The answer to your question depends on the payer.

Long-standing AMA instruction allows you to report each cytology preparation as a distinct service. In other words, if the pathologist needs to examine both a direct smear (88104, Cytopathology, fluids, washings or brushings, except cervical or vaginal; smears with interpretation) and a concentrated smear (88108 Cytopathology, concentration technique, smears and interpretation [e.g., Saccomanno technique]) to reach a diagnosis, you can bill separately for each preparation.

Beware Medicare: CMS has established different criteria for billing these codes, which you'll need to follow for Medicare or any payers that use the same rules. The Correct Coding Initiative (CCI) edits bundle codes within the 88104-88112 group, meaning that you cannot bill different preparations together for the same specimen.

The CCI Policy Manual instructions state that Medicare considers different cytology preparations a "duplicate" service. If the pathologist uses two preparations, you should bill only for the more comprehensive procedure.

That means you should bill your example to Medicare as 88108. You should not additionally report 88104. Even though using modifier 59 (Distinct procedural service) would override the edit pair, you should not use 59 when you're billing for one specimen. Reserve modifier 59 for cases when the pathologist examines a direct smear and a concentrated smear from two different specimens on the same day.