College of American Pathologists
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  Billing brief: the facts behind FNA codes






July 2007
Feature Story

James P. Almas, MD

Cytopathologic evaluations of fine needle aspirates are reported with codes 88172–88173. CPT code 88172 Cytopathology, evaluation of fine needle aspirate; immediate cytohistologic study to determine the adequacy of specimen(s) is a physician code and cannot be reported when a cytotechnologist assesses specimen adequacy. To clear up potential confusion, the CAP Economic Affairs Committee offers this explanation of the code: The unit of service for this code is best understood as per site, per evaluation, and is not dependent on the number of slides examined. The number of “passes” or “aliquots” of material obtained does not necessarily define the service.

An example of a real case study will provide further clarification.

A radiologist performs a fine needle aspiration, or FNA, of a lung lesion in a patient with lung and liver lesions. The radiologist makes one “pass,” “two passes,” or more, and material is simultaneously presented to the pathologist for evaluation. There may be one slide or many slides stained by Pap, Diff-Quik, or H and E, or all three. The pathologist makes a determination (professional judgment) that there is insufficient tissue for a diagnosis. The pathologist transmits the information to the radiologist, and this episode (evaluation) constitutes one unit of 88172.

To continue the example, 10 minutes later the radiologist now sends material from an FNA of the liver for immediate evaluation by the pathologist. (The radiologist may have made one “pass” or more into the liver. The material may include one slide or more. There may be one “aliquot” or more.) The pathologist now needs to start the evaluation of the new specimen. In this example, the pathologist determines that malignant cells are present in this sample and communicates this information to the radiologist. This evaluation constitutes one unit of 88172.

To continue the example further, the radiologist now goes back to sample the lung lesion again. The pathologist is now presented another set of slides to evaluate. The slides are examined. The pathologist now confirms (on this sample) that malignant cells are present. This constitutes a third 88172 unit of service.

Two important concepts are illustrated in this clinical example. First, the unit of service for each 88172 is independent of the number of slides, “passes,” or “aliquots” generated during the FNA procedure. As illustrated here, the unit of service for code 88172 is best defined as per site, per evaluation. Second, multiple units of service on the same day of service are a common occurrence and depend on the clinical circumstances for each patient.

The proper billing of CPT codes 88172 and 88173 has been detailed in a number of publications including CPT Assistant and CAP TODAY. The coding advice given here is consistent with the previous advice provided by the CAP and the American Medical Association.

Dr. Almas is the CAP’s member of the AMA CPT Advisory Committee and vice chair for CPT issues for the CAP Economic Affairs Committee.


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