Pathology/Lab Coding Alert

Can you ignore Medicare's laboratory date-of-service (DOS) policy if you bill for the professional component (PC) of physician pathology services? Not always.

It's true that the DOS policy applies to clinical lab tests and the technical component (TC) of physician pathology services, but read on and you'll see that sometimes you have to follow the rules even if you're billing for the PC.

Let the Medicare fee schedules guide you to an easy way to remember which codes are subject to the guidelines:

1. Tests paid under the clinical laboratory fee schedule (CLFS)

2. Pathology services listed with modifier TC (Technical component) on the Medicare Physician Fee Schedule (MPFS) -- but only when you're billing the TC.

Pathologists beware: Now that the lab DOS policy applies to TC of pathology (as of January this year), you can expect an impact on billing for a wide scope of tests such as the following:

• surgical pathology tissue exams (88302-88309)

• non-gynecological cytopathology (88104-88112, 88160-88162, and 88172-88173)

• adjunct services, such as special stains (+88313- +88314)

• immunohistochemistry (88342, 88360-88361)

• in situ hybridization (ISH) (88365-88368).

If the rule applies to clinical lab tests and the TC of pathology physician services, how can it impact your pathologist PC services? Global billing.

"Each line item takes one DOS, so billing globally (TC and PC together) means you must follow the TC DOS rule," explains Pamela Biffle, CPC, CPC-I, CCS-P, ACS-DE, principal for PB Healthcare Consulting and Education in Fort Worth, Texas.

Distinguish global billing: The MPFS lists some codes with modifiers TC and 26 (Professional component). "If you report one of those codes without a modifier, you're billing for both the technical and professional component," Biffle says. That's global billing.

What if you're an independent lab that bills for the PC and TC of pathology services, but you performed the components on two different dates of service? "Global billing is not appropriate for this instance," according to CMS.

Do this: If you have different dates of service for the TC and PC of a pathology service that your independent lab reports, bill separate line items using modifiers TC and 26.

CMS modified the DOS policy to include direction about cases of TC/PC with different dates of service, effective Aug. 24. You can read the transmittal at www.cms.hhs.gov/MLNMattersArticles/downloads/MM6457.pdf.