scuttles site-of-service Pap smear plan
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 independent
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 category."
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 code.
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.
Reprinted from February 1999 CAP