Pathology/Lab Coding Alert

Question: Our laboratory recently started performing a new molecular test for CF. The test results are "read" by our Director of Cytogenetics, who holds a PhD, rather than one of the pathologists. Can we bill for the interpretation using 88291?

Wisconsin Subscriber

Answer: No. Billing 88291 (Cytogenetics and molecular cytogenetics, interpretation and report) when the PhD lab director "reads" the CF molecular test results is inappropriate.

Doctor required: 88291 is a physician service paid under the Medicare physician fee schedule (PFS), so you can't bill the service for a non-M.D. or D.O. It is a professional-only code not billable with modifiers TC (Technical component) or 26 (Professional component). Also, Medicare does not list 88291 on the clinical laboratory fee schedule (CLFS) or as an APC on the outpatient prospective payment fee schedule.

Problem 2: The other problem with your question is that 88291 is not the correct interpretation code for a molecular diagnostics cystic fibrosis test such as CFTR common variants. Rather, you should list the interpretation of these tests using 83912 (Molecular diagnostics; interpretation and report). You can report this code with no modifier when a PhD reads the test, and Medicare will pay for the service under the CLFS. If a pathologist interprets the test, report 83912-26 (Professional component), and Medicare will pay for the service at a higher rate on the PFS.