Pathology/Lab Coding Alert

Question: I-ve always understood that we can report consultations on slides or tissues referred from an outside lab on a "per case" basis. Lately, we-ve received denials from Medicare when we report multiple units of 88321. Has something changed?

Missouri Subscriber

Answer: Yes, something has changed. The Oct. 1, 2007, update to the National Correct Coding Initiative Policy Manual provides a new expectation for the following codes:

- 88321 -- Consultation and report on referred slides prepared elsewhere

- 88323 -- Consultation and report on referred material requiring preparation of slides

- 88325 -- Consultation, comprehensive, with review of records and specimens, with report on referred material.

The manual states, "CMS payment policy allows only one unit of service for CPT codes 88321, 88323 and 88325 per beneficiary per provider on a single date of service." CMS goes on to instruct coders not to report the codes on separate claim lines with modifiers in an attempt to receive payment for the services.

Correct coding: You are correct that the unit of service for these consultation codes is the case or accession, which may include several specimens from a single surgical pathology or cytology case -- that's according to the American Medical Association. If you receive a consultation request for slides or tissues from two different dates or two unrelated organ systems, however, you have two "cases" or two "accessions."

For example: You have two accessions if your pathologist consults on slides from a lesion excision taken on one date and slides from a margin re-excision taken two days later.

Do this: Regardless of the number of accessions, you should not bill Medicare for multiple units of 88321, 88323 or 88325. Nor should you bill Medicare for any combination of those codes (such as 88321 and 88323) based on CCI edits and the Policy Manual.

You may continue to bill multiples of these codes to other payers, as appropriate, when your pathologist performs outside consults on separate surgical pathology or cytology cases in the same day.