Consult question 88321


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I work for a Dermatopathogist and the doctor is asking below question, does anyone know?

For consult cases where multiple specimens are sent, it is preferable from a patient care standpoint to be able to generate a single report. This is what is done at other UCs. In that case, if for example there is a medicare patient with 5 separate specimens that I review and issue a single report for, would you be able to charge the 88321 five times on five separate days, or would it only bill as a single consult? I prefer not to wait and issue a separate report on 5 separate days.


Minneapolis, Minnesota
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You can only bill 88321 per original date of service. So if all 5 specimens were from the same original DOS that would be one 88321 charge. If the 5 specimens are each from a separate original DOS (and the patient is not medicare) you can bill 88321x5 on a single report


Brainerd, MN
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I have something to provide regarding billing 88321 - it has a MUE of 1 with MAI of 2 (that means that you are allowed to bill this charge once per a day of service). Please tell me that we are billing the "received" date - the actual date your facility received the slides/block and not the collection date.
If you are billing the "collection date" that is "IN MY OPINION" is simply wrong because it will bundle with the charges the folks that acquired the specimen and had it presented to their pathology department for review are trying to bill their pathology charges with and someone is going to be denied. You would bill for the date it was received.
Personally, I think that the accessioning team has gotten lazy, or are not update on education; and they bulk some of this under the same Accession # when if they actually SHOULD HAVE accessioned cases by EACH INDIVIDUAL "received date" that some of our pathologists may be getting paid for more than one consultation.

Let me provide a hypothetical example (none of this exists - I am simply making this up as I type)

Example A:
SUO20-14596 - SOMEFACILITYSOMEWHERE (03/01/2020)
Received 16 slides and a unstained block (A12)
Facility received date 04/10/2021

Example B:
SUO21-00056 ANOTHERFACILITY (02/02/2021)
Received 6 slides and a unstained block (B6)
Facility received date 04/20/2021

Lets pretend that it is today 5/12/2021 - and we try to bill the the specimen SUO20-14596 dated 03/01/2020 with the collection date; you are already timely. It happened 14 months ago, I do not know of any insurance that will pay anything beyond the 12 months threshold. Why would we bill the collection date? We would want to again, bill the date the slides/block was received for reimbursement.

Another scenario - ok, the pathologist reviews both consultations (all under the same Accession number again that I cringe at) and provides their professional interpretation for each consultation on the same pathology report. Yes (again in my opinon), we should bill the received dates but they are under one accession with one DOS per the HARs probably in Epic. However, there were seriously two different consultations performed - but only one should actually be billed due to the MUE (medical unlikely edit) of 1 per DOS because it was all accessioned under one DOS. Our facility follows the MUE established and if CMS is going to only pay for one - I guess so be it.

I will continue to ask those important questions. I'm also super glad that commercial will pay for subsequent 88321 charges; probably by appeal in my opinion.

Thank you for listening and have a great evening,
Coding Specialist 3 - Pathology Coder
Claim Analyst & Denials Specialist