Ob-Gyn Coding Alert

Screening Pap Smear Can Be Billed with E/M Service

Starting April 1, 1999, a change in Medicares payment policy will allow for the billing of an E/M problem visit at the same time a Medicare patient has a Pap smear performed and coded with the HCPCS code Q0091 (screening Papanicolaou smear; obtaining, preparing and conveyance of cervical or vaginal smear to laboratory). A recent HCFA memorandum (HCFA Pub. 60 B) changes the Correct Coding Initiative (CCI) edits for both codes Q0091 and G0101 (cervical or vaginal cancer screening, pelvic and clinical breast examination). The G0101 changes went into effect on January 1, and were covered in OCA in February.

Before April 1, 1999, the CCI edits are such that Medicare wont cover the collection of a Pap smear specimen at the same time a significant, separately identifiable E/M service was provided. For example, if a woman fit Medi-
cares description of being at high risk for cervical cancer, and was coming in for an annual Pap screen, and at the same time complained of hemorrhoids (455.0) that needed an E/M service, you were not permitted to bill for both. The choice was to bill for one service or the other, or have the patient come back on a different day for the separate service.

The new HCFA memorandum states: Effective with the CCI update for April 1, 1999, Q0091 and a separately identifiable E/M service can be billed by the same physician on the same day as the Q0091. Modifier -25 should be utilized in those situations. This PM [program memorandum] supersedes the information contained in PM B-98-16 under the heading Carrier Billing Requirements which discusses E/M services and G0101 or Q0091.

While this change appears to solve the reporting dilemma for ob/gyn practices, it remains to be seen how the payments will work out. People need to remember that the Q0091 was originally developed by Medicare to report collection of a screening Pap smear specimen at the time of an E/M service that Medicare would not pay for, says Melanie Witt, RN, CPC, MA, program manager for the American College of Obstetricians and Gynecologists Department of Coding and Nomenclature. Previously, the collection of the specimen was included in the covered E/M service that Medicare was paying for when the reason for the Pap smear was diagnostic rather than screening. If the woman presents with symptoms and you decide to do a Pap smear as a diagnostic test, then its not screening, and the E/M service will be related to the collection of the specimen and a modifier -25 may not be appropriate. What we dont know is how Medicare carriers will decide to define the phrase separately identifiable E/M service when deciding whether to allow billing for both the E/M service and the Pap smear collection.

Witt goes on to say that for now, coders should take this memorandum at face value, report both the E/M service with the Pap smear collection code and see what happens. She also reminds coders that if the E/M service is not related to the reason the Pap smear specimen was collected (e.g., annual screening plus evaluation of hemorrhoids), to make sure the E/M service is appended with the -25 modifier and then watch their EOBs closely. Until we get to try a few cases and see if they are bounced back, we wont know how this is going to work.

Note: The HCFA memorandum mentioned above can be found on the Web at:

http://www.hcfa.gov/pubforms/transmit/b986060.htm.