Pathology/Lab Coding Alert

Question: When our lab processes a fine needle aspiration to evaluate adequacy while the patient is still in the operating room, can we charge for a technical service if a cytotechnologist -- not a pathologist -- performs the adequacy check?

Idaho Subscriber

Answer: You are correct to assume that you cannot bill a professional service if a pathologist does not perform the adequacy check (88172, Cytopathology, evaluation of fine needle aspirate; immediate cytohistologic study to determine adequacy of specimen[s]).

But the answer to your question about charging for the technical service depends on whom you ask.

Answer 1: The Medicare physician fee schedule lists 88172 with modifiers TC (Technical component) and 26 (Professional component), assigning a value to each part of the service. The hospital outpatient prospective payment system APC schedule also acknowledges a technical fee for 88172. Based on these indicators, you can bill an 88172 technical service when a cytotechnologist performs the FNA adequacy check (under pathologist supervision).

Answer 2: The College of American Pathologists (CAP) has stated, "CPT code 88172 is a physician code and cannot be reported when a cytotechnologist assesses specimen adequacy" (CAP Today, July 2007). This reflects an earlier CAP statement made in CAP Today, September 2006: "While a cytotechnologist may prepare the smears and ancillary preparations, and he or she may even evaluate the smears, an 88172 cannot be billed for the cytotechnologist's services."

You should establish a consistent 88172 policy for your lab with the assistance of your compliance officer.