Most providers do the biopsy and aspiration the same: anesthetize, may incision, insert 15-gauge Rosenthal aspiration needle and obtain aspirate, remove, insert 11-gauge biopsy Jamshidi needle (same incision), obtain biopsy and remove.
On occasion bilateral biopsies (diagnosis dependent) are needed. In this case 2 procedures are performed on 2 separate sites. This is rare and should be documented as bilateral bone marrow aspirate and biopsy.
So, when the insurance is Medicare and both the aspiration and biopsy are done through the same incision you would report 38221 and G0364. If both are performed on a patient with commercial/managed care insurance using the same incision, then you would onlyreport 38221 (since 38220 is bundled per CCI edits). Some commercial/managed care payers may recognize G0364.
If both services are performed in different ‘sites' (meaning “in different bones or two separate skin incisions over the same bone.”) or encounters then you would report 38221 and 38220 -59 to all payers (including Medicare). Documentation will need to support the ‘separate site' in order to justify appending modifier -59.
Additional 59 support: CMS posted “Modifier 59 Article: Proper Usage Regarding Distinct Procedural Service” on its CCI overview Web page
<http://www.cms.hhs.gov/NationalCorrectCodInitEd/>.
In one study, the Office of Inspector General (OIG)<http://oig.hhs.gov/oei/reports/oei-03-02-00771.pdf> found that coders inappropriately used modifier 59 more often with 38220/38221 than any other code pair. So you want to take extra care to append modifier 59 only when appropriate.
Best regards -