Pathology/Lab Coding Alert

Focus on Cytopathology Bundling Rules--We'll Show You When to Override Edits

Don't bill separately for 88184-88189 cell review

If you're billing separately for a cytology smear exam with flow cytometry--watch out. You could be unbundling.
 
Regardless of the specimen--peripheral blood, aspirates, tissue or cytology specimens--the lab prepares a cellular suspension before performing flow-cytometry analysis. Can you bill for the original specimen exam, a slide evaluation from the cell preparation, and the flow cytometry? If you do, you could be double-dipping and risking fraud charges. Bill for Separate Specimen Exam Pathologists often integrate both a specimen exam and flow cytometry for the evaluation of hematolymphoid cancers. "You can code separately for the tissue or aspiration exam along with flow cytometry codes for the same specimen," says William Dettwyler, MT-AMT, president of Codus Medicus, a laboratory coding consulting firm in Salem, Ore.

Example: The pathologist extracts a bone-marrow aspirate, examines direct smears from the aspiration, and processes and examines a cell block. Based on findings indicating myeloid leukemia, the lab concentrates the remaining aspirate and runs an immunophenotyping flow-cytometry panel on the cell suspension, including markers CD45, CD34, CD15, CD14, CD13, CD33, CD7 and CD19.

You should individually code the bone marrow aspiration and exam, the cell block, and the flow cytometry as follows:

• CPT 38220 --Bone marrow; aspiration only

• 85097--Bone marrow, smear interpretation

• 88305--Level IV--Surgical pathology, gross and microscopic examination, cell block, any source

• 88184--Flow cytometry, cell surface, cytoplasmic, or nuclear marker, technical component only; first marker

• +88185--...each additional marker (list separately in addition to code for first marker) (Report seven units of 88185, one for each marker beyond the first.)

• 88187--Flow cytometry, interpretation; 2 to 8 markers. Flow Cytometry Includes Morphologic Cellular Evaluation In the prior example, the lab concentrates the aspirated cells, enhancing the cell suspension for flow cytometry. But even if the pathologist examines smears or thin-layer preparation slides as part of the flow cytometry service, you should not separately report cytology code 88108 (Cytopathology, concentration technique, smears and interpretation [e.g., Saccomanno technique]) or 88112 (Cytopathology, selective cellular enhancement technique with interpretation [e.g., liquid-based slide preparation method], except cervical or vaginal). "The flow cytometry service includes a cytology smear interpretation," Dettwyler says.

Bottom line: Don't use two different cytology procedure codes for the same specimen. "Report the most extensive cytopathology service that the pathologist performs on a given specimen to reach a diagnosis," Dettwyler says.  NCCI Bundles Cytopathology Codes The National Correct Coding Initiative edits confirm that you should select only one cytopathology method for a given specimen. NCCI bundles flow cytometry codes 88184-88189 with both cytology codes 88108 and 88112. Based on "standards of medical practice," CMS contends that the pathologist will routinely perform a morphologic cytology exam as part of a flow cytometry panel to interpret the findings and provide [...]
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