Pathology/Lab Coding Alert

Problem: CMS interprets 88361 more narrowly than its definition. "Although CPT does not distinguish between manual methods such as the pathologist's visual count and automated methods such as ChromaVision, CMS has stated that we cannot use 88361 to describe the manual services," Padget says.

Specifically, CMS states in the NCCI policy manual: "CPT code 88361 should not be used to report any service other than quantitative immunocytochemistry by digital cellular imaging. Digital cellular imaging includes computer software analysis of stained microscopic slides." You can access the manual on the Internet at http://www.cms.hhs.gov/physicians/cciedits/chap10.pdf.

Do this: Instead of 88361, you should use 88342 to report manual IHC tumor morphometry, at least to Medicare. The College of American Pathologists (CAP) says, "To report quantitative/semiquantitative immunohis-tochemistry performed by manual methods, use CPT code 88342 ..." (CAP Today April 2004, available online at http://www.cap.org/apps/docs/cpt_coding/article_index.html).

But what about non-Medicare payers? "CAP is encouraging members to follow CMS instructions until CPT changes can settle the automated/manual controversy," says Joan Logue, BS, MT-ASCP, principal with Health Systems Concepts Inc. in Longwood, Fla. "I would encourage practices to follow CAP's guidance and use 88361 only for automated tests until CPT code changes address the issue -- the additional dollars in the short term are not worth problems with private payers," she says.

Another option: Not all experts agree that you should follow Medicare's lead in using 88361 only for automated tests. "This is a case where laboratories and pathologists should report one way for Medicare and payers who have adopted Medicare coding rules, but a different way for all other payers," Padget says. Use 88361 only for automated IHC tumor morphometry for Medicare, but use it for both automated and nonautomated procedures for non-Medicare-type payers, Padget instructs. "Written response from the AMA's CPT Information Services unit supports this coding," Padget says.

Opportunity: Future editions of CPT should clarify coding for manual versus computer-assisted methodology, according to CAP. "We welcome a universal coding solution that recognizes the additional work in performing a quantitative manual IHC beyond the qualitative code 88342," Padget says.

If the pathologist performs IHC tumor morpho-metry for multiple antibodies, report 88361 for each. You may have to add modifier -59 (Distinct procedural service) for multiple units, depending on your carrier's edit requirements.

Coding example: The pathologist receives an invasive breast cancer specimen and performs estrogen receptor and progesterone receptor quantitation (ER/PR) using ChromaVision ACIS. The pathologist also quantifies Her-2/neu with the ACIS image analyzer. You should bill for three units of 88361.