Pathology/Lab Coding Alert

Performing pathology services from afar using telecommunications and computer systems may be the wave of the future, but who's paying and how? Because pathology services do not require "face-to-face" time with the patient, Medicare payment for telepathology is way ahead of many other telehealth services and is not subject to the same restrictions.

Pathologists use "static" telepathology for consultations on images referred from distant sites, and some are beginning to use "dynamic" telepathology for real-time interpretation of frozen sections while the patient is in surgery at a remote location. Although issues such as licensure, confidentiality and liability are not fully resolved, Medicare and other insurers have had a history of paying for telepathology services.

Payers typically cover telepathology as they would the same diagnostic services without the use of telecommunications transmissions. Even so, "always check with your insurer to be certain of coverage," says Yukako Yagi, MD, director of telepathology at the University of Pittsburgh Medical Center.

Use Consultation, Frozen Section Codes

Report telepathology using the same codes you would use for the conventional service, according to Yagi and a CMS spokesman. The same coverage rules apply, such as supervision and medical necessity requirements, and the payment amounts are the same, according to the CMS source. A local Medicare carrier, however, may deny a specific telepathology service if, for example, the carrier considers it investigational.

"For a pathology consultation on slides viewed via telepathology, report 88321 (Consultation and report on referred slides prepared elsewhere)," says Gail Barker, MBA, pathology department administrator and associate director of finance for telemedicine at the University of Arizona Health Sciences Center in Tucson. The pathologist performs this service when a physician from the other site requests it, and the pathologist provides a consultation and reports on the findings. The code description does not distinguish how the pathologist views the slides, whether in person or via the computer.

"In some cases we report telepathology consultations using 88325 (Consultation, comprehensive, with review of records and specimens, with report on referred material)," Barker says. Only use this code if the pathologist provides a review of the complete patient record, not just the pathology reports submitted with the current telepathology request.

Report frozen sections via telepathology just as you would report the conventional service, Yagi says. Use 88331 (Pathology consultation during surgery; first tissue block, with frozen section[s], single specimen) and 88332 ( each additional tissue block with frozen section[s]). Because the originating lab prepares the frozen sections, that lab should bill the technical component of the service using modifier -TC (Technical component), and the off-site pathologist who interprets the frozen sections should bill for the professional component using modifier -26 (Professional component).

Medicare Telehealth Rules Do Not Apply

Medicare rules for telehealth services include certain conditions of payment, such as requiring originating sites to be located in rural health professional shortage areas (HPSA) or counties not in a metropolitan statistical area (MSA), as outlined in Program Memorandum AB-02-052 dated April 29, 2002. These restrictions do not apply to telepathology, according to the CMS spokesman, because Medicare doesn't consider it a telehealth service.

Similarly, coders should not use telemedicine modifiers -GT (Via interactive audio and video telecommunication system) or -GQ (Via asynchronous telecommunications system) for telepathology services, according to the CMS source. Nor can the originating site bill the telehealth fee using Q3014 (Telehealth originating site facility fee), he says.

Rather, Medicare carriers have discretion to cover and pay for telepathology under Section 2020A of the Medicare Carriers Manual, which describes services not requiring a face-to-face patient encounter that are delivered via a telecommunications system, such as the interpretation of an x-ray, electroencephalogram, electrocardiogram or tissue samples. The transmission of a tissue sample image via telecommunications system does not change the methodology for payment, the CMS source says. The same payment amount, billing code and carrier jurisdictions apply.