Friday, July 17, 2020

AMA October CPT to Revisit Lab Clinical Consultation Codes; What's Up?

In a post a few days ago, I noted that AMA CPT for October will consider deleting the current clinical lab consultation codes (80500,80502) and replacing them with a quartet of four codes that will better accommodate complex and prolonged clinical consultations on lab test results.

See my earlier post here.  See the AMA PDF here.  Stakeholders can request more information about the new code plans from AMA by July 24 and comment by July 31.   Note that you have to "justify" your interest in the code as a stakeholder - AMA doesn't defined this very clearly.  In my experience, AMA sometimes accepts very short justifications of a phrase or two, and sometimes asks for more info as "justification" and I've provided two paragraphs.

Added - I've seen the 4 code applications (through the mechanism just described) - while I can't comment on the code proposals due to AMA confidentiality, I can confirm that they may be viewed as a "big deal" in some groups.

Added - See a successor blog; 80500/502 are the only codes restricted by AMA to a single physician specialty.  Here.

What are Current Codes?

The current codes are 80500 for a "clinical pathology consultation" without patient records review and 80502 for a "clinical pathology consultation" with records review.  The AMA text of the codes is pretty short.  CMS requires that the clinical pathology consultation be requested by a clinician - the lab can't just spontaneously decide to tack a $23 consultation onto a $4 CBC at its own initiative.

Most consultations of these types are directly billed by physicians, based on the CMS provider utilization database.  

However, in 2017, one lab, Genoptix, billed for about 6000 clinical consultations (here).  Genoptix garnered 16% of all clinical consultation fees for the 2017 Part B database (about $220,000 out of $1.1M).  The next highest billers of 2017 clinical consultations were a doc in Texas and 2 docs in Florida who billed for about 1000 clinical consultations each (80502) for circa $60-70,000.

RUC and Current Codes

80500 is valued for about $23 for 13 minutes of physician time and 8 minutes of lab tech time.  80502 is valued at about $76 for about 42 minutes of physician time and 8 minutes of lab tech time.

80500 was billed 100,000 times in 2010 and 2011 - but only 20,000 times in 2018.  It was billed 80% by pathologists and 20% by clinical laboratories.

80502 was billed 24,000 times in 2011 and 2012, and 14,000 times in 2018.  It was billed 75% by pathologists and 18% by clinical laboratories.

Neither code has a RUC vignette or justification/rationale in the subscription-based RUC database at AMA.

More Complex Genomic Interpretations

Just a couple advanced molecular codes have re-interpretations built in, which have some similarities to a clinical consultant.  81415 Exome pays $4780 at CMS, and a reinterpretation 81417 pays $320.  81425 Genome pays $5031 at CMS, and a reinterpretation 81427 pays $2337.     

Slides Consultation

There are different codes for glass slides consultation, 88321-5.