Pathology/Lab Coding Alert

Aspirations and needle core include 'stick' codes

When a pathologist acquires a needle biopsy or aspiration, you may have considered using a separate injection code--don’t. Codes 10021-10022 and 38220-38221 include the G-code needle stick, according to the latest National Correct Coding Initiative edits (NCCI, version 11.3).

A large number of the new NCCI edits affect drug administration codes G0347-G0358 that Medicare implemented in 2005. Presumably, these edits will cross over to new CPT Codes that should replace these temporary codes in January 2006.

Bundles Affect FNA, Bone Marrow

According to NCCI 11.3, G0351 (Therapeutic or diagnostic injection [specify substance or drug]; subcutaneous or intramuscular), G0353 (Intravenous push, single or initial substance/drug) and G0354 (Each additional sequential intravenous push [list separately in addition to code for primary procedure]) are components of the following procedures:

• 10021--Fine needle aspiration; without imaging guidance

• 10022--…with imaging guidance

• 38220--Bone marrow; aspiration only

• 38221--…biopsy, needle or trocar

• 38240--Bone marrow or blood-derived peripheral stem cell transplantation; allogenic

• 38241--…autologous.

NCCI 11.3 also adds two other G codes as components of 38220-38221--G0345 (Intravenous infusion, hydration; initial, up to one hour) and G0347 (Intravenous infusion, for therapeutic/diagnostic [specify substance or drug]; initial, up to one hour). That means the FNA or bone marrow procedures include the injection or infusion services, so you shouldn’t report an additional G code for a single procedure that your pathologist performs.

Watch for: Remember that you should use the 10021 and 38220 code families only when your pathologist procures the specimen. Entirely different codes describe a pathologist’s FNA or bone marrow specimen examination.

Don’t report 10021 or 38220 if your pathologist does not extract the cells, says Peggy Slagle, CPC, billing compliance coordinator at the University of Nebraska Medical Center in Omaha.

Procedures Include Injection

Medicare says you can’t code an injection or infusion separately as a “standard of medical/surgical practice.” Payers consider injection to be an inherent part of most procedures, says Dawn Hopkins, senior manager for reimbursement with the Society of Interventional Radiology.

Either CMS is seeing widespread abuse of the new injection G codes by physicians trying to bill for them with many procedures, or the new edits are a precaution. CMS may simply be trying to block all of the code combinations that physicians do not commonly bill together, Hopkins says.

Don’t miss: NCCI gives these edits a modifier indicator of “1,” so if the situation warrants, you may be able to use a modifier to override the edit pairs. If the procedures represent two different patient encounters, for instance, you can use modifier 59 (Distinct procedural service) to get paid for both codes of the edit pair.

Consultations Bundled, Too

Pathologists have to watch for another edit pair added in NCCI 11.3. According to the code editor, 88323 (Consultation and report on referred material requiring preparation of slides) is a component of the more-extensive procedure 88325 (Consultation, comprehensive, with review of records and specimens, with report on referred material).

Pathologists perform an 88323 or 88325 service when another institution sends tissue and/or slides for a second-opinion consultation. When the lab prepares slides from referred tissue and the pathologist provides diagnostic information based solely on the examination, use 88323. If the pathologist also reviews the full patient history, such as surgical notes and oncology reports, you should use 88325 whether or not the lab prepares any new slides. The new NCCI edit confirms that you should not code both 88323 and 88325 for the same case.

Exception: Unlike most surgical pathology procedures, the specimen is not the unit of service for 88323 and 88325. Rather, you should code these services per “case” on which the physician requests the pathologist’s consultation. You can override the 88325/88323 edit pair only if the pathologist performs separate consultations on two different cases on the same day. 

Stay Abreast of New Edits With This Free Resource

Finding out if your claim denial is based on an NCCI edit is easy. You can access the complete, current list of NCCI edits without cost at the CMS Web site cms.hhs.gov/physicians/cciedits/default.asp, says Laureen Jandroep, OTR, CPC, CCS-P, CPC-H, CCS, director and senior instructor for CRN Institute, an online coding certification training center based in Absecon, N.J.

The same Web page also includes links to documents that explain the edits, including the NCCI Policy Manual for Part B Medicare Carriers, the Medicare Carriers Manual, and an NCCI Question-and-Answer page.