
Management of Pathology Practices
April 2008
Dissecting the Physician Quality Reporting Initiative (PQRI)
Laura Edgeworth, HTL (ASCP), CPC
Manager, Coding Compliance, PSA, LLC
– A MED3OOO Company
The pathology industry became eligible for participation in
the newest phase of the Centers for Medicare and Medicaid Services (CMS)
Physician Quality Reporting Initiative (PQRI) as of January 1, 2008. The overall goal of the program is to promote
improved reporting mechanisms of histologic grading and pathologic staging [pT
(primary tumor) and pN (regional lymph nodes) categories] for breast and
colorectal cancer cases. Medicare is
providing incentive for improved reporting mechanisms by reimbursing physicians
1.5% of all Medicare-allowed charges for the 2008 calendar year. Only those pathologists performing
evaluations on breast and colorectal cancer cases are eligible for
participation. The incentives are
applied by provider rather than by practice, so there is a possibility that
specialized pathologists (dermatopathologists, cytopathologists) will not participate.
Criteria for Bonus Collection
It is important to note that all participants will not meet
the criteria for collecting the PQRI bonus.
Medicare has established a baseline volume of total cases that must be
reported to qualify for the measure, but the actual number of cases required
has not been determined. In addition,
those with qualifying volume must report the PQRI measures in 80% of the
eligible cases in order to be included in the measure. This is determined by dividing the number of
cases meeting the reporting requirements (numerator) by the total number of
eligible cases (denominator). The CMS identifies
qualifying (denominator) cases by cross-referencing CPT-4 and ICD-9-CM codes
and they have been monitoring the eligible cases since 1/1/2008. Medicare does not require practices to
register to participate in the program; therefore, their data system identifies
all PQRI eligible cases for all providers.
Physicians cannot bill the PQRI reporting measures retrospectively, so
it is imperative to begin reporting measures as soon as possible, if you wish
to participate in the PQRI program.
Reporting Eligible Cases
Eligible breast cases are reported with codes from
either the 174 (Malignant neoplasm female breast) or 175 (Malignant neoplasm
male breast) diagnosis code series in addition
to the 88307 or 88309 CPT code. Eligible colon cases are reported with
codes from either the 154 code series (Malignant neoplasm of colon) or codes
154.0, 154.1 and 154.8 (Malignant neoplasm of rectum, rectosigmoid junction) in
addition to the 88309 CPT code. In order
to qualify for the numerator, the applicable level II CPT code, with or without
modifier, must be indicated. The chart
below outlines the codes and the determination for use:
|
3260F: |
The pT
and pN category and histologic grade are documented. |
|
3260F-1P:
|
The pT
and pN category and histologic grade are not
documented, but medical reason(s) for exclusion is documented in the pathology report (ex: re-excision without
residual tumor). |
|
3260F-8P: |
The pT
and pN category and histologic grade are not
documented, and reason for exclusion is
not documented in the pathology report. |
Identifying Ineligible Cases
PSA has assisted clients in preparing for the PQRI program
and has instituted an internal quality control measure to identify the
applicable cases. While a manual review
is currently being performed, computer updates similar to the CMS system are
being installed. To date, this review
process has identified multiple instances in which cases are submitted for PQRI
inclusion, but actually do not meet PQRI criteria. In each of the cases, the diagnosis code precludes
the case from eligibility. The examples
below represent the most commonly excluded cases:
·
In-situ
carcinomas are listed separately from primary cancers in the ICD-9
classification. For example, ductal
carcinoma in-situ and lobular carcinoma in-situ of the breast are coded as 233.0
(Carcinoma in situ of breast and genitourinary system; breast). The 233.0 is not included on Medicare’s list
of eligible codes, so the 3260F is not reportable in these cases. The 3260F is reported if the specimen is
diagnosed with invasive cancer in addition to the in-situ component.
·
Metastatic
cancers are also listed separately from primary cancers in the ICD-9
classification. Metastatic cancer is
diagnosis coded based on the site of the secondary neoplasm rather than the
primary cancer. For example, an axillary
lymph node with metastatic breast cancer is diagnosis coded as 196.3 (Secondary
and unspecified malignant neoplasm of lymph nodes; Lymph nodes of axilla and
upper limb), thereby bypassing the PQRI requirement.
·
Malignancies
of the small bowel are coded with the 152 code series (Malignant neoplasm of
the small intestine, including duodenum), which is not a PQRI-covered diagnosis
code.
Identifying Non-qualifying but
Eligible Cases
There are also a few circumstances in which the PQRI measure
will identify non-qualifying cases as eligible.
The pathologists’ diagnosis is submitted as the ICD-9 code when
diagnosis coding for pathology. When the
pathologist’s findings are normal, the coder should report the signs and/or
symptoms leading to the specimen evaluation.
Suppose a liver biopsy (CPT code 88307) is submitted for evaluation and
the only clinical information provided is “invasive right breast cancer.” The pathologist renders a diagnosis of
“negative for malignancy.” The coder would report code 174.9 (Malignant
neoplasm of female breast; Breast (female), unspecified) as the diagnosis code,
making the case eligible for the PQRI denominator. However, it was never the intent of the PQRI
program to capture data on liver specimens. The best way to prevent these cases from affecting
the PQRI denominator is to provide more thorough clinical information in the
pathology report. For example, clinical
history documentation such as “liver lesion” or “PET scan positive” directly
relates to the liver biopsy and provides the medical necessity for biopsy and
pathologic examination.
Reference Material and Tools
PSA has implemented the following processes to support
affiliated practices in reporting this data:
·
Audio
conferences were held on December 14th and 18th to
explain the measures and provide an overview of the program. The audio files of
these conferences are available.
·
Development
of certain system enhancements designed to aid in identifying those cases which
may be eligible for the PQRI measures in order to assist practices in their
participation.
·
Tools
including: sample pathology report
documentation, worksheets for documenting and reporting quality measures and
decision trees for each measure, and will be available to answer your
questions.
·
February
2008 Coding Challenge providing pathologists an opportunity to test their PQRI
skills.
The information
referenced above is available on the PSA Extranet at www.psaaffiliates.com.
For additional information on PQRI pathology reporting
measures and descriptions please:
·
Contact
PSA or your billing service provider
·
CMS
website: www.cms.hhs.gov/PQRI
·
CAP
website: www.cap.org
For more information on the
Physician Quality Reporting Initiative, please contact PSA at 800-832-5270 or psa@psapath.com. PSA provides billing, marketing, and business
solutions to pathologists nationwide.