Pathology/Lab Coding Alert

Question: If a physician submits a cervical biopsy and the pathologist also reviews past Pap smears from the same patient, can we separately report the Pap review in addition to the biopsy? If so, what code should we use?


Georgia Subscriber
Answer: The pathologist must correlate all malignant or premalignant Pap findings with subsequent histopathology as a standard of care under the Clinical Laboratory Improvement Amendment (CLIA). The process is known as cyto-histo correlation, and labs routinely document it as a part of quality assurance, and you cannot charge separately for that.

Circumstances exist, however, that justify a separate code for the Pap review. When a discrepancy exists in cytopathology and histopathology findings and the treating physician requests a consultation from the pathologist to further interpret the incongruity and suggest a clinical course of action, you can report a consultation service.

Report 80500 (Clinical pathology consultation; limited, without review of patient's history and medical records) for a requested cyto-histo consultation on slides from the same institution. If another institution submits slides to the pathologist for the requested review, report 88321 (Consultation and report on referred slides prepared elsewhere), according to the June 2000 CAP Today.

Some coders have been confused because the National Correct Coding Initiative Policy Manual states that you should not use 80500 with a pathology service that includes a physician interpretation. But this instruction means that you should not report 80500 to describe the included interpretation service--you may use it for a separate consultation service.

To report either 80500 or 88321 for a cyto-histo correlation, you must meet all four consultation requirements, according to section 15020 of the Medicare Carriers Manual:

1. The attending physician must request the consultation (Medicare stipulates that standing orders do not suffice for the request)

2. The consultation must relate to abnormal findings

3. The pathologist must exercise medical judgment

4. The pathologist must file a written report.