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,
Dana Chock, CPC, CANPC, CHONC, CPMA, CPB, RHIT
Coding Specialist 3 - Pathology Coder
Claim Analyst & Denials Specialist