Pathology/Lab Coding Alert

Question: When our pathologist reads an abnormal Pap smear, we charge 88141. When the pathologist later examines the patient's cervical biopsy, he reads the cytology slide again to ensure that the Pap and biopsy results correlate. In addition to 88305 for the biopsy, should we also charge 88141 again for looking at the Pap smear a second time?

Ohio Subscriber

Answer: No, you should not charge an additional 88141 (Cytopathology, cervical or vaginal [any reporting system], requiring interpretation by physician) for the pathologist "re-reading" a Pap smear to correlate with biopsy findings.

The Clinical Laboratory Improvement Amendments (CLIA) mandates cyto-histologic correlation between biopsies and Pap smears with findings of high-grade squamous intraepithelial lesion (HSIL) or carcinoma. In other words, you-re required as a standard-of-practice to correlate the findings of cytology (Pap smear) with histology (biopsy). As such, the service is a "quality assurance" measure, and you can't bill for that.

CLIA does not specify how or when the correlation takes place, so the law does not require the pathologist to re-read the original Pap at the time of the biopsy. However, if your pathologist routinely re-reads the original Pap slide to ensure correlation between cytology and the surgical biopsy, as you-ve stated, then the service appears to be a quality assurance measure.

Exception: If, on the other hand, the pathologist reviews a Pap smear due to a discrepancy between the previously-reported cytology findings and the biopsy findings, you might be able to charge for the service.

Do this: Rather than billing 88141 for re-reading the Pap, the appropriate code is 80500 (Clinical pathology consultation; limited, without review of patient's history and medical records) if the pathologist reviews the Pap smear and biopsy to determine the reason for a lack of cyto-histo correlation, and to suggest further testing or course of action for the clinician.

Caution: Although 80500 is the appropriate code for the service when the pathologist reviews a Pap and biopsy from within the same institution, you must fulfill certain "consultation" requirements to be able to use this code. According to Section 15020 of the Medicare Carriers Manual, you must meet these four conditions to use code 80500:

1. The patient's attending physician must request the consultation, and standing orders do not suffice

2. The consultation must relate to a test result that lies outside the clinically significant normal or expected range in view of the condition of the patient

3. The consulting physician must document results in a written report included in the patient's medical record

4. The service must involve the exercise of medical judgment by the consultant physician.

Use different code for referred slides: If the pathologist reviews slides from an outside institution to evaluate a discrepancy in cytologic and histologic findings, you should not use 80500. Instead, you should use 88321 (Consultation and report on referred slides prepared elsewhere) to report a consultation on slides that a physician from another institution submits.