Wiki Mohs issue - Path was sent out!

[AprilSueMadison]

Dr performed Mohs on a pt. Obviously to bill for Mohs the doctor needs to act both as the surgeon and the pathologist.

Here is what happened....

Stage 1 - Specimen was prepared in office, microscopic exam revealed atypical basaloid proliferation. THEN I have a note here that states "The lesion is more consistent with <insert random thing here>, will send to Outside Path Lab"

Stage 2- Specimen was prepared in office, he worked as the pathologist here and notes that the margins are clear of tumor.

So it looks like he worked as the surgeon and pathologist...but also sent it out.

I have an outside lab report for this as well. So I know he really sent it out. What in the world do I do for this situation? He did this twice last week and he's never done this before.

 

[CatchTheWind]

Here's what Dr. Alexander Miller posted in his coding column in the AAD newsletter (https://www.aad.org/dw/cracking-the-code/2013/september)

"In some select instances there is a valid medical care reason for sending out some of the excised tissue for formalin-fixed histopathologic evaluation by an outside lab. This is not strictly prohibited by the Mohs LCDs and the MLN publication, but such a practice may trigger a Medicare Recovery Audit Contractor (RAC) audit or a non-payment for the surgery or a demand for a refund. The RAC Contractors are actively monitoring Mohs surgery when pathology is billed by different provider.... One should be prepared to appeal such a decision by submitting a valid medical reason for sending out the tissue for an outside evaluation, and by referring to the AAD ?Position Statement on Appropriate Uses of Paraffin Sections in Association with Mohs Micrographic Surgery,? available on the AAD website at www.aad.org/Forms/Policies/ps.aspx."