Pathology/Lab Coding Alert

Question: Our pathologist evaluated a direct FNA specimen smear for diagnosis, then further processed the sample through an "enrichment" process and evaluated another slide. Can we bill separately for the FNA direct smear and enriched smear?

Tennessee Subscriber

Answer: Probably not. Medicare and payers that follow Medicare CCI rules don't allow you to bill together 88173 (Cytopathology, evaluation of fine needle aspirate; interpretation and report) and 88112 (Cytopathology, selective cellular enhancement technique with interpretation (eg, liquid based slide preparation method), except cervical or vaginal) for the same FNA specimen.

CCI bundles 88112 as a column 2 code with 88173, meaning that you should not report the codes together for the same specimen.

The College of American Pathologists (CAP) also advises that code 88173 "encompasses the fine-needle aspirate cytologic evaluation and interpretation with report, irrespective of the method and type of preparation and the number of slides." In other words, code 88173 includes the work of 88112, according to CAP.

Exceptions: CPT^® instruction does not restrict billing these two codes together, as it does some other cytopathology preparations. So if your payer allows it, and your practice chooses not to adhere to the CAP guidance on this point, you may bill the codes together. Also, if the pathologist evaluates an FNA specimen (88173) and an enriched smear from a distinct specimen source (88112), you may bill the codes together for Medicare payers by appending an appropriate modifier, such as 59 (Distinct procedural service) to 88112.