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October 2004

Q: What date of service should we report for archived specimens?

A. Do not report the date the specimen was collected as the date of service. Guidelines from the Centers for Medicare and Medicaid Services specify the correct date of service is the date the specimen is obtained from archives. The final rule, published Nov. 23, 2001, states that "for laboratory tests that require a specimen from stored collections, the date of service should be defined as the date the specimen was obtained from the archives." However, the final rule does not define how long a specimen must be stored before it is considered to be archived.

CMS has received numerous requests from laboratories to issue a national standard that clarifies when a stored specimen can be considered archived. CMS proposed to further clarify the date of service provisions related to archived specimens that appear in the proposed ruling issued Dec. 24, 2003. Those provisions are that a specimen must be stored for more than 30 calendar days to be considered archived—specimens stored 30 days or less would have a date of service of the date the specimen was collected. This provision is under review and is not expected to be finalized until early 2005.

Q: What is the appropriate use for the new ICD-9 code 795.08? Should it be billed when the Pap smear is unsatisfactory and interpreted or when the Pap smear is unsatisfactory and reported as such with no interpretation possible?

A. The publication ICD-9-CM 2005 contains several changes for cervical cytology to differentiate between diagnoses based on Pap test results and those based on biopsy results. Classifications under diagnosis code 795.0 were expanded to more accurately reflect the terminology used in the revised Bethesda system for ASC-US, AGUS, dysplasia, and unsatisfactory and nonspecific abnormalities. Unsatisfactory specimens can be billed if they are processed completely and examined by the laboratory. Specimens that are unsatisfactory for evaluation are reportable with diagnosis code 795.08. If the sample was unsatisfactory and another Pap test needs to be taken, clinicians should report 795.08 as the primary diagnosis to justify that the service is medically necessary. Labs should use code 795.08 as a secondary diagnosis with the appropriate Pap screening test to indicate the cytologic service was performed but the specimen was unsatisfactory. The reason for inadequacy must be specified if the specimen is processed and examined. Those unsatisfactory Pap tests that are rejected—for example, if there is no label or a slide is broken beyond repair—should not be billed because they have not been processed completely and examined. CMS no longer allows the 90-day grace period for annual ICD-9-CM updates, effective for dates of service on and after Oct. 1, 2004. Providers must bill using the diagnosis code that is valid for the date of service.


Frequently asked questions about CPT are published bimonthly in “Capitol Scan.” This section of CAP TODAY is a product of the CAP Economic Affairs Committee.

The codes and descriptions listed here are from Current Procedural Terminology, 4th ed., CPT 2006. CPT 2006 is copyrighted by the American Medical Association. To purchase CPT books, call the AMA at 800-621-8335.

For more information about CPT coding, visit the CPT Coding Resource Center on the CAP Web site.