Reprinted from February 1999 CAP TODAY
The Health Care Financing Administration has revised a payment policy
that would have determined the relative value of a physician's interpretation
of a Pap smear by whether the service was provided in a hospital or an
HCFA officials now say the agency will pay the same for such interpretations
regardless of the site of the service. As with other physician fee schedule
services, geographic adjustments will determine final payment for Pap
smear interpretations in specific areas.
The government had published a two-tiered system of payment in the November
final rule on the 1999 physician fee schedule. In that rule, the 1999
relative value unit, or RVU, for a Pap smear interpretation when provided
in a hospital was set at 0.76, while the RVU for a service provided in
an independent laboratory was set at 1.01. The difference? The resource-based
practice expense RVU, which was set at 0.31 for a hospital-based pathologist’s
interpretation and 0.56 for an independent laboratory physician’s interpretation.
The higher practice expense values published in November for services
provided by independent laboratories mistakenly included an allocation
for costs associated with the screening Pap smear, payment for which is
made separately under the clinical laboratory fee schedule.
A HCFA program memorandum to all Part B carriers announced the change,
which took effect Jan. 1. The 1999 RVUs for the Medicare physician Pap
smear, regardless of where the service is provided, are 0.42 for physician
work, 0.31 for practice expense and 0.03 for malpractice, giving the service
a total value of 0.76.
Medicare began on Jan. 1 paying separately for physician Pap smear interpretations
for outpatients if the laboratory screening personnel suspect an abnormality
and the physician reviews and interprets the Pap smear, even if the Pap
smear is interpreted as showing no abnormality.
The physician fee schedule final rule that established separate payment
for Medicare outpatient physician interpretations of Pap smears reiteriated
a clinical laboratory improvement amendments requirement for such review.
CLIA ‘88 regulations require a pathologist’s confirmation of abnormalities
found during an initial Pap smear screening. Such abnormalities, the regulations
state, include “reactive or reparative changes, atypical squamous
or glandular cells of undertermined significance, or to be in the premalignant
(dysplasia, cervical intraepithelial neoplasia or all squamous intrepithelial
lesions including human papilloma virus associated changes) or malignant
An article on the use of CPT coding for Pap smear interpretations in
the December 1998 issue of the “CPT Assistant” newsletter, published
by the American Medical Association, also touched on the CLIA requirement.
In the article, the College, working with the AMA, responded to the question,
“Is the code for physician interpretation of a Pap smear, 88141,
to be used to report rescreening of negative Pap smears for quality control?”
The published response said that, considering the interpretation code
terminology and the CLIA requirements, negative Pap smears that do not
require a physician’s interpretation, including smears reviewed for quality
control purposes, should not be coded with the physician interpretation
The interpretation code should be used to report physician interpretation
of a smear identified as abnormal in initial screening. This includes
smears interpreted to be showing suspicious or malignant cells, epithelial
cell abnormality (atypical cells of undetermined significance, for example)
or cellular changes simulating epithelial cell abnormality, such as repair,
radiation effect, and cellular changes associated with viral infection,
the article states.