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Understanding the complexities of molecular pathology coding

Samantha Sandy, MS LCGC, CPC, CPCO

Molecular diagnostics have emerged as powerful tools for precise disease detection and personalized treatment. While the science is evolving at a rapid pace, the complexity of billing and coding lag behind.

One of the foremost challenges in molecular billing and coding lies in the accuracy and specificity of codes. Unlike more straightforward medical services, molecular tests require codes that account for a wide range of variables, including type of test, specific genes or analytes analyzed, specimens used, methodology, and the purpose of the test, such as diagnostic, screening, or therapeutic.

With around 20,000 genes in the human genome and 160,000 genetic tests, the availability of unique procedural coding is bleak in comparison (1, 2). Without precise coding, payers are left guessing about what occurred on the bench. Incorrect or vague coding can lead to claim denials, delayed reimbursements, compliance issues — and financial toxicity for patients.

Healthcare professionals across medical, laboratory, and payer industries must stay abreast of constantly evolving code sets, such as Current Procedural Terminology (CPT) codes, Healthcare Common Procedure Coding System (HCPCS) codes, and International Classification of Diseases (ICD) codes, some of which publish new code sets quarterly. Each molecular test may require multiple CPT codes to accurately capture the procedure, while others may be more correctly billed as a single code.

Often tests rely on nonspecific codes, further complicating billing.

Challenges in interpretation and implementation

Although the testing market continues to expand, available code sets have advanced little (2). Three key areas are ripe for innovation and collaboration: technology, standardization, and administration.

Under technological advances, next-generation sequencing (NGS), for example, has revolutionized the field by allowing the simultaneous analysis of multiple genes. It has also introduced new complexities in coding. Coders must differentiate among types of tests (DNA sequencing, RNA sequencing, copy number analyses, methylation), a task complicated by the continuous emergence of new tests and methodologies.

When a new test materializes, yet no specific coding is available, billers rely on the ambiguous 81479 unlisted procedural code. With so many tests billed as 81479, ambiguity leads to lower or no reimbursement as payers navigate the conundrum of enforcing medical necessity. PLA codes are highly specific, but many are obtained prior to clinical utility studies, leading to a lack of reimbursement (See box). As technology advances, PLA codes lack fluidity for modifications in gene content and methodology, hastening obsolescence.

Types of molecular codes

Molecular pathology coding can be broken into subgroups that define the type of molecular testing being performed.

  • Tier 1 codes often are single-gene tests whose descriptors may specify gene content, methodology, sample type, and/or clinical use.
  • Tier 2 codes are arranged by level of complexity and have descriptors providing suggestions of applicable genes/ genetic content.
  • Genomic sequencing procedures provide a single code to encompass simultaneously assayed genes or regions.
  • Multianalyte assays with algorithmic analyses offer combinatorial information of biomarker/genetic tests with biological details of the patient as an algorithmic score or probability.
  • Proprietary Laboratory Analysis (PLA) codes introduce the opportunity for specificity by providing a unique alpha-numeric code for a laboratory or manufacturers’ test; however, they do not reflect an assessment of clinical utility.

A lack of standardization compounds the problem. There is often inconsistency in how different payers interpret and implement coding guidelines. This lack of standardization burdens laboratories and healthcare providers, who must navigate a maze of payer-specific rules.

Furthermore, federal and state health programs can differ dramatically from commercial and employer-funded health plans in their enforcement of correct coding. As an adjunct to relying on nonspecific coding, organizations develop CPT identifiers to describe each unique test. These are managed by an independent organization and are only made available to payers or laboratories for whom they contract. Without all the layers of the industry adopting a standard system, the CPT identifiers lack context and challenge consistency.

Once claims for molecular testing are submitted to payers, administrative challenges begin. Coders may rely on laboratory details, test menus, and diagnosis codes to piece together the specifics of a test. The same code may be used for different assays, such as performing sequencing of BRCAl in germline and somatic clinical scenarios. The resultant coding of a claim may be unreliable in providing necessary details for enforcement of medical policy.

The administrative burden extends outward as laboratories and clinics identify documentation within patient charting to justify the service billed as they navigate distinctive payer policies. Claim adjudication is a resource-intensive process for all. Traversing these complexities requires proactive communication, ongoing education, and a keen understanding of regulatory and policy updates.

Case illustration: From clinic to claim

Consider the journey of Whitney, a 45-year-old patient with breast cancer. Whitney’s genetic counselor orders a multigene panel to identify hereditary cancer risks. The laboratory secures prior authorization for a hereditary breast cancer panel, performs the test, and submits the claim. Despite meeting all preauthorization requirements of medical necessity, the claim is denied due to discrepancies in coding interpretations between the lab (billing 81162) and the payer (policy directs billing 81432).

Resolving such issues involves appeals and resubmissions, consuming time and resources. Without resolution, Whitney may be left financially responsible, or the laboratory may not receive any reimbursement. Effective communication between labs, payers, and clinics is essential to streamline this process and minimize delays in patient care.

Moving forward: Collaboration and standardization

To overcome these challenges, stakeholders must continue to collaborate on standardizing coding practices and guidelines, including:

  • Policy alignment: Harmonizing coding guidelines and policies across different payers can help ensure uniformity in coding practices, reduce administrative burdens, and improve reimbursement processes.

  • Expanded expertise and yraining resources: Increasing the number of professionals with expertise in both genetics and coding can lead to more accurate, efficient, and consistent coding. Identify easy and streamlined methods to provide education and training on correct coding to all stakeholders.

  • Technological adaptation: Keeping coding systems updated with the latest advancements in genetic testing technology is crucial for maintaining relevance and accuracy. Determining a path forward in coding that allows both fluidity and specificity is integral to reducing burdens on the healthcare system and barriers to patient care.

Conclusion

Molecular pathology coding is undeniably complex, but understanding the reasons behind these complexities is the first step toward a better system for all involved, including patients. By fostering collaboration among labs, clinics, and payers, and by continuously updating and standardizing coding practices, the healthcare industry can improve the efficiency and accuracy of molecular pathology coding. This effort is essential to providing high quality care and ensuring that the benefits of genetic testing are fully realized for all patients. Samantha Sandy, MS LCGC, CPC, CPCO, is a genetic counselor and certified coder currently working in the payer industry. +Email: [email protected]

References

  1. Salzberg SL. Open questions: How many genes do we have? BMC Biology 2018; doi:10.1186/s12915-018-0564-x
  2. Phillips KA, Deverka PA, Hooker GW, et al.. Genetic test availability and spending: Where are we now? Where are we going? Health Affairs. 2018; doi: 10.1377/hlthaff.2017.1427

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