May 29, 2007
Niles Rosen, MD
National Correct Coding Initiative
Correct Coding Solutions, LLC
P.O. Box 907
Carmel, Indiana 46082-0907
Dear Dr. Rosen,
The College of American Pathologists would like to comment on Phase 4 of the proposed Medically Unlikely Edits (MUEs) that are scheduled for implementation October of this year. The attached file provides our comments about specific MUEs (Excel, 31 K). However, we also would like to object to imposing any MUEs on certain codes. These codes fall into two distinct categories discussed below.
First, we do not believe an MUE should be set for consultation codes 88321, 88323 and 88325 because we believe that implementing an MUE of “1” for these codes represents an arbitrary interpretation of these codes that is clearly contrary to historical coding practices. It is, in fact, not a question of medical likelihood but payment policy. The attached document lays out some of the supporting arguments for this statement.
Second, the College has identified five codes, which are highlighted in yellow on the attached spreadsheet, that we believe should not be subject to any MUE. They are either methodology CPT codes and/or not analyte specific. Many of these codes are used to detect antibodies of infectious agents. The AMA CPT 2006 states the following when billing with this group of CPT codes “When multiple tests are done to detect antibodies to organisms classified more precisely than the specificity allowed by available codes, it is appropriate to code each as a separate service.” Therefore it is appropriate to perform and bill any one of these CPT codes in multiples greater than one unit of service per date of service based on the clinical circumstances. They represent a variety of clinically significant tests that physicians rely on for diagnosis, and the adoption of an MUE would provide an unnecessary barrier to their use.
We thank you for the opportunity to respond to this latest set of MUEs. If you have any further questions regarding our response, please contact Janemarie Mulvey at the College of American Pathologists at (202) 354-7110.
W. Stephen Black-Schaffer, MD, FCA
CAP Representative to the Correct Coding Initiative
John D. Stewart, CMS/OFM
Lisa Zone, CMS COTR
Valeria Allen, CMS COTR
Michael D. Maves, MD, Executive Vice-President, AMA
Karen O’Hara, AMA
Linda Dietz, Correct Coding Solutions