Hello
jperkins
May I please respond? It may be lengthy, but I feel I may have the information you need for your question.
Okay, the way that I have been taught is that if the pathology department (pathologist's) receives a specimen since I became a pathology coder in 2012 "it is clearly at their sole discretion on how to evaluate it"; They are the arbiter and they will do what is necessary to drive that final diagnosis.
In my thought process why would a consultation be any different?
First - The pathologist receives an "in house" specimen from a surgeon within the facility that provides a stomach biopsy and after they review with H&E stain and see something that requires additional work and they need to confirm with the H. Pylori stain to validate that H. Pylori organisms are present. Along with no one telling them to apply alcian blue special stain for goblet cells to determine metaplasia.
Next - The pathologist receives a consultation to review. Again, they are the arbiter and get to process this specimen (slides received, paraffin block) on exactly what they need to do to perform their professional interpretation here.
What if the dermatopathologist thinks that for example it is melanoma for example and sends this very specimen out as a referral.
The pathologist only received the H&E slides but no other "stained" slides; therefore, they performed "melanoma markers" Melan-A, HMB-45, with SOX10 to validate if indeed the patient has melanoma or not on the received slides or the paraffin block.
During my coding career, I worked for a facility that sent many consultations out because they did not have INHOUSE THOSE "immunohistochemical stains" to evaluate and REQUIRED THAT second opinion. I have also worked at that large facility that had all THOSE seriously "immunohistochemical stains" necessary to provide that final diagnosis.
I am going to provide the NCCI guidelines here
https://www.cms.gov/files/document/medicare-ncci-policy-manual-2023-chapter-10.pdf
This is a free resource that I will copy and paste.
2. CPT codes 88321-88325 describe surgical pathology consultation services to
review slides, tissues, or other material obtained, prepared, and interpreted at a different location
by a different pathologist and referred to another pathologist for a second opinion. These codes
shall not be reported by pathologists reporting a second opinion on slides, tissue, or other
material also examined and reported by another pathologist in the same provider group.
Medicare generally does not pay twice for an interpretation of a given technical service (e.g.,
ECGs, radiographs, etc.). CPT codes 88321-88325 are reported with one unit of service
regardless of the number of specimens, paraffin blocks, stained slides, etc.
When reporting CPT codes 88321-88325, providers/suppliers shall not report other pathology
CPT codes such as 88312, 88313, 88187, 88188, 88189, 88342, 88341, 88344, etc., for
interpretation of stains, slides or other material previously interpreted by another pathologist.
Revision Date (Medicare): 1/1/2023
X-13
CPT codes 88312, 88313, 88342, 88341, and 88344 may be reported with CPT codes 88321-
88325 only if the physician performs these staining procedure(s) and interprets these newly
stained slide(s). CPT code 88323 may be reported for consultation and report on referred
material if the physician performs additional necessary de novo routine staining (e.g.,
hematoxylin-eosin, Giemsa) on additional slides. CPT codes 88321-88325 shall not be reported
with a face-to-face evaluation of a patient. If a physician provides an E&M service to a patient,
and, in the course of the E&M service, specimens obtained elsewhere are reviewed as well, this
review is part of the E&M service and is not reported separately. Only the E&M service shall be
reported.
My concern here is that you would not have updated 88321 to 88323.
88321 is "consultation and report on referred slides prepared elsewhere".
88323 is "consultation and report on referred material requiring preparation of slides".
Let our pathologist's do what they do and render the final diagnosis (medical condition) processing like they are supposed to do.
There was nothing in the NCCI stating that they had to state why they applied a stain or two on referral slides.
Again, not a doubt in my mind that they are doing what they are supposed too here.
If you need a real-life example. I had a large lipoma the size of a large egg removed just a few years back personally; with complex skin closure.
I wasn't going to sleep well until I had this MDM2 FISH done here on my personal specimen.
Again, our local facility did not have the FISH to conduct this testing and it was a send out to the Mayo that was deemed benign by them.
If you have any additional questions, please feel free to reach out.
Have a fantastic afternoon!
Dana