Pathology/Lab Coding Alert

Separate sites on single specimen justify code pair -- and an extra $51 Reporting intraoperative touch preps and frozen sections from the same specimen seemed on the way out -- again -- when the National Correct Coding Initiative (NCCI) bundled 88331 with 88334 in April 2006.

But now our experts indicate that you can recoup $51 for a touch prep during surgery (88334, Pathology consultation during surgery; cytologic examination [e.g., touch prep, squash prep], each additional site) on the same specimen as a frozen section (88331, ... first tissue block, with frozen section[s], single specimen) even though the edit pair remains in effect -- but only under certain conditions. NCCI Should Limit You -- Not Stop You When NCCI paired 88331 and 88334, the edit seemed to directly contradict CPT direction about how to use the codes, says Ernest J. Conforti, MSHS, SCT (ASCP) MT, director of anatomic pathology operations at North Shore-Long Island Jewish Health System, headquartered in Great Neck, N.Y.

Problem: NCCI bundles 88331 and 88334 as a column 1/column 2 edit pair, but modifier indicator -1- means you can use modifier 59 (Distinct procedural service) to report the codes together under certain circumstances. Based on common usage of modifier 59, many coders understood the acceptable circumstance to mean separate specimens -- which from a practical standpoint meant that you could never bill 88331 and 88334-59 to Medicare for the same surgical consultation.

Solution: The -specimen- is not really the focus of this edit after all, says Dennis Padget, MBA, CPA, FHFMA, president of DLPadget Enterprises Inc., a pathology business practices publishing company in Simpsonville, Ky. -If the pathologist performs the frozen section and touch prep on different sites of the same specimen, such as the tumor and a separate tumor margin, you can override the 88331-88334 edit using modifier 59,- he says. In other words, the focus of the edit is -site,- not -specimen.- NCCI Clarifies Edit Pair In response to a written inquiry regarding the 88331-88334 edit pair, Niles R. Rosen, MD, medical director of NCCI, clarified appropriate conditions to report the two codes together, Padget says. -You can bill for both a frozen section [88331] and touch prep [88334-59] when the pathologist performs the two procedures at separate and distinct sites on the same specimen,- he says.

For instance: The pathologist carries out a frozen section (88331) on the tumor for intraoperative diagnosis and also performs an intraoperative touch prep (88334) at a margin of the resection distinct from the area of the tumor examined by frozen section.

AMA and CAP Instruction Concurs Documentation from the AMA and the College of American Pathologists (CAP) also confirms that you can report 88331 and 88334 together for different sites on the same specimen
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The AMA [...]