Wiki Place of Service CPT 88172

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mloftus

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As a privately owned Independent Lab we typically bill services with POS 81. However, we are now performing 88172 (FNA adequacy) on site at a private office. We do not have a rent agreement just perform 88172 in their IR suite. (FNA 88173 will subsequently be rendered back at our lab with POS 81) Are we allowed to bill place of service 81 for the on-site evaluation (88172) as well?
 
Hi mloftus,
How do you justify billing POS 81 with an "intraoperative procedure" that needs POS 22 or 21 or even 11 (How do you bill independent laboratory for 88172 if they weren't there?)
Well, unfortunately your team is probably eating those charges performed in the private office until you have figured out the billing piece
Let me ask you this question personally as a coder, how would you feel receiving an invoice or EOB from POS 81 versus POS 22, 21, or 11 (office)? I challenge most EOBs I receive. So would be excited for feedback please.
Thank you for listening and have a wonderful evening,
Dana, CPC, CANPC, CHONC, CPMA, CPB, RHIT
 
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We have not yet billed for the service to all payers to date. Most of our local contracted payers have provided documentation based on our contract for POS. (Some advised "other" POS based on our contract) One payer remaining is Medicare and for the point you raised we paused. Dana do you have experience particularly with privately owned independent labs? I appreciate any feedback!
 
Hi mloftus,
No, I do not have experience with privately owned independent labs but I know that "independent lab" drives the POS 81 and maybe from just from my simple minded thought process I was over thinking that POS 21, 22, or 11 would be more appropriate for an "intraoperative" procedure?
May I ask a question please?
Is the pathologist's performing the "intraoperative FNA adequacy" procedure also the same provider in the privately owned independent lab performing the "final interpretation"? I have clients that will bill one pathologist performing the "intraoperative FNA interpretation" and the slides are sent to the pathology department for final review by the pathologist's on site. (I don't see those claims to see if one pathologist's performing the intraoperative FNA is driving a different POS from the other pathologist's).
But now that I am thinking about this this evening, you are probably billing Service Provider, Billing Provider, Department and Place of Service with "Independent Lab" that will drive the POS 81. Have you performed a "billing sample"? Let me explain.
Take like a predetermined amount of cases (like 10-12) and bill them with "Independent Lab" for Service Provider, Billing Provider, Department and Place of Service? And follow up in 45 business days. Were you paid? If not, Why? They will usually state POS issue (and denial would be much quicker than the 45 business day threshold I offered).
I am hopeful you figure out your billing woes and thank you for listening,
Dana Chock, CPC, CANPC, CHONC, CPMA, CPB, RHIT
 
Dana I do appreciate your advice. To answer your questions:
Most likely the same pathologists will render the onsite 88172 and return to the lab for 88173 evaluation. However, since we are a group practice that is not always 100%.
Years ago before my involvement with the lab, for a short period of time the onsite 88172 was performed and billed POS 81. All were paid. But not sure I want to rely on that given the description of POS81. I have researched CMS, our MAC, etc given our Independent Lab status and have not been able to find a good answer as it related to billing Medicare. Our contracted payers obliged me with confirmation of either 81 or 99 (other)
Again, happy to take any advice.
 
mloftus said:
Dana I do appreciate your advice. To answer your questions:
Most likely the same pathologists will render the onsite 88172 and return to the lab for 88173 evaluation. However, since we are a group practice that is not always 100%.
Years ago before my involvement with the lab, for a short period of time the onsite 88172 was performed and billed POS 81. All were paid. But not sure I want to rely on that given the description of POS81. I have researched CMS, our MAC, etc given our Independent Lab status and have not been able to find a good answer as it related to billing Medicare. Our contracted payers obliged me with confirmation of either 81 or 99 (other)
Again, happy to take any advice.
Click to expand...
Dana, What is your thought if the -26 is only billed as rent is not engaged?
 
mloftus said:
Dana, What is your thought if the -26 is only billed as rent is not engaged?
Click to expand...
88172 with modifier 26 seems almost appropriate. But someone else is getting the technical. But you do not know with a private office without a rent agreement. Are they billing the TC thinking they actually deem that charge, or do they think you simply are? Or should you just be billing global? Communication at this point and POS (place of service needs to be CLEARLY established here). Make sure you have those credentialed at the right place and right time to bill those charges okay.
Thank you for listening and have a great evening,
Dana Chock, CPC, CANPC, CHONC, CPMA, CPB, RHIT
 
Dana,
Clearly discussed: No rent agreement in place as our pathologist is scheduled at specific time in their IR suite. Also, Radiology office is not billing TC. My only stretch with the PC/26 is due to no rent agreement.
Medicare is my concern.
 
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