Compliance Perspectives: Compliance Warning: Watch Out for 2015 Laboratory Drug CPT® Code Changes

The American Medical Association (AMA) and the Centers for Medicare and Medicaid Services (CMS) have posted the preliminary new, revised, and deleted CPT® codes for 2015. The Drug Testing and the Therapeutic Drug Assay sections of the CPT book are being completely revamped. Whenever we see changes of this magnitude, we know there will be compliance problems in the transition from the old way to the new. This article will highlight the upcoming changes, contrast them with the way drugs have been coded in the past, and offer compliance warnings for the new codes.The AMA CPT Editorial Board received a request to add numerous new CPT codes for drug testing. The board created a Quantitative Drug Task Force, which consisted of members of the Pathology Coding Caucus (the group that normally proposes laboratory CPT changes), pharmacists, reference laboratories, insurance representatives, and physicians, including pain medicine doctors. It took almost two years to create the new codes.The actual CPT codes have not been released as of the publication date of this article, but instead placeholder codes have been provided by the AMA until the codes are officially published in September. There are 65 new codes, seven revised codes, and 34 deleted codes in the drug testing section. There are now two sections: the qualitative, presumptive drug screens and the quantitative, definitive drug analysis section, which includes confirmations. Previously confirmation and quantitation of drugs were spread out between the drug section, the therapeutic drug assays, and the chemistry section of the CPT book.

Qualitative Screening
All of the current drug screening codes 80100, 80101, and 80104 are being deleted. There has been quite a bit of confusion with the AMA CPT codes and the CMS Healthcare Common Procedure Coding System (HCPCS) codes (G0431 and G0434) in the past. The two sets of coding had different descriptions and usage, which created the confusion and compliance problems. Recently other payers have started requesting that laboratories bill drug screens using HCPCS codes instead of the AMA codes. This has created compliance issues because the units of service between CPT and HCPCS are not the same. The new drug codes were created with the hope that they would be compatible with all payers, including Medicare. The 80101 was billed for each drug or drug class with a typical claim containing seven to nine units of service. The G0431 was once per day of service, and then only for high-complexity testing. The 80104 was for point-of-care drug screening, but the description didn’t adequately describe that usage. The G0343 was a mix 80101 and 80104 but had the additional confusion of having CLIA complexity in the description of the code.

The new codes separate the drugs into Class List A and B. There is also provision for the methodology used in the testing, whether it is a simple point-of-care cup or matrix-assisted laser desorption/ionization-time of flight technology. Class A drugs are those that are included in the point-of-care methods and are also available on the multichannel chemistry analyzers. Class B drugs are those that are usually single-test procedures or are not typically screened with every Class A drug. The two tables are appended at the end of this article.

2015 CPT 2015 Description
Notes on Usage
2014 Code(s) that Are Replaced
801XXX1 Drug screen, any number of drug classes from Drug Class List A; any number of non-TLC devices or procedures, (e.g., immunoassay) capable of being read by direct optical observation including instrumented-assisted when performed (e.g., dipsticks, cups, cards, cartridges), per date of service Point of care dipsticks and cups. Can bill only once per date of service. 80104, G0434
801XX2A Drug screen, any number of drug classes from Drug Class List A; single drug class method, by instrumented test systems (e.g., discrete multichannel chemistry analyzers utilizing immunoassay or enzyme assay), per date of service Drug screening performed on larger instruments. Bill this code once, no matter how many drugs in this class were performed. This differs from the 80101, which was billed once for each drug or drug class. 80101, G0434
801XX4A Drug screen, presumptive, single drug class from Drug Class List B, by immunoassay (e.g., ELISA) or non-TLC chromatography without mass spectrometry (e.g., GC, HPLC), each procedure These are drugs not typically found on dipsticks or on multichannel chemistry analyzers. Various
801XXX6 Drug screen, any number of drug classes, presumptive, single or multiple drug class method; thin layer chromatography procedure(s) (TLC) (e.g., acid, neutral, alkaloid plate), per date of service Close to 80100 description, but instead of each procedure, it is each date of service. 80100, G0431
801XXX7 Drug screen, any number of drug classes, presumptive, single or multiple drug class method; not otherwise specified presumptive procedure (e.g., TOF, MALDI, LDTD, DESI, DART), each procedure A catch all code for other methodology that does not fit into one of the previous codes.

 

There are five new drug screen CPT codes for 2015 as defined in the preceding table.

Quantitative or Confirmation Drug Testing
The drug confirmation code of 80102 (Drug confirmation, each procedure) is being deleted in 2015. This code was too general, which created problems for payers not knowing what they were paying for, and for laboratories that need reimbursement better matched to the cost of the confirmation. One size did not fit all anymore. The new CPT codes are more defined by having a code for each drug and drug class. Some of them are tiered depending on the number of metabolites that are being quantified. There still are the not otherwise specified codes that have the description of “Drug(s) or substance(s), definitive, qualitative or quantitative, not otherwise specified; 1 to 3, 4 to 6, and 7 or more (801XY45 – 801XY47).” Laboratories will need to be careful and selective in their use of correct codes in 2015.

Several codes in the drug section are being renumbered. For example, benzodiazepines were 80154. They now have two codes, 801XY5 and 6, depending on the number being reported. Some drugs that previously had their own CPT code, such as salicylate (80196), are now part of a larger drug class (Analgesics, non-opioid). A different code would be used to screen for salicylate, which is in the Class B screening list. Some codes that were in the chemistry section are being deleted and moved and renumbered in the drug section. An example of that is 83925, Opiate(s) drug and metabolites, each procedure. A table of all of the definitive drug codes follows at the end of the article.

Class A Drugs Reference List Class B Drugs Reference List
Alcohol (Ethanol) Acetaminophen
Amphetamines Carisoprodol/Meprobamate
Barbiturates Ethyl Glucuronide
Benzodiazepines Fentanyl
Buprenorphine Ketamine
Cocaine metabolite Meperidine
Heroin metabolite (6-monoacetylmorphi) Methylphenidate
Methadone Nicotine/Cotinine
Methadone metabolite (EDDP) Salicylate
Methamphetamine Synthetic Cannabinoids
Methaqualoe Tapentadol
Methylenedioxymethamphetamine (MDMA) Tramadol
Opiates Zolpidem
Oxycodone Not otherwise specified
Phencyclidine
Propoxyphee
Tetrahydrocannabinol (THC) metabolites (marijuana)
Tricyclic Antidepressants


Changes in the Chemistry Section of CPT
The chemistry section of the CPT codes is from 82000 to 84999. There were 20 drug testing codes in the chemistry section. They are being renumbered or deleted and in some cases renamed and now will reside with the rest of the drug codes in the drug testing section of CPT.

Codes that Have Description Changes
A handful of codes retain their current number but have had description changes that either clarify the use of the code or change entirely the use of the code. A few of the significant changes are:

  • »80162—Digoxin now is Digoxin, total, and a new code is created for Digoxin, free.
  • »80299—This previously was for quantitation of any drug, not elsewhere specified. It now is only to be used for quantitation of a therapeutic drug, not elsewhere specified.
  • »82541—Column chromatography/mass spectrometry has added verbiage to indicate this code is for use only in nondrug analysis.
  • »84600—This is the volatiles code. The alcohols have been removed because they now will be coded using the new Alcohol CPT code in the drug section.

Compliance
All of these changes have potential to create coding and compliance issues. The correct qualitative drug screen must be selected, based on methodology, to avoid upcoding. Care must be taken when selecting the new quantitative CPT codes as to the correct class and correct tiers. Codes that have been used for years now may have changed meaning and purpose. There are several codes that are very similar to each other and caution must be exercised when selecting the correct CPT.

Paul Keoppel can be reached at Paul.Keoppel@imail.org, 801-507-8038.

Definitive Drug Assays
801XY2 Alcohol biomarkers; 1 to 2 801XY36 Antiepileptics, not otherwise specified; 7 or more 801XY10 Methadone
801XY3 Alcohol biomarkers; 3 or more 801XY31 Antipsychotics, not otherwise specified, 1 to 3 801XY17B Methylenedioxy- amphetamines
801XY1 Alcohols 801XY32 Antipsychotics, not otherwise specified, 4 to 6 801XY17C Methylphenidate
801XY44 Alkaloids, not otherwise specified 801XY33 Antipsychotics, not otherwise specified, 7 or more 801XY7 Opiates, one or more
801XY18 Amphetamines; 1 to 2 801XY4 Barbiturates 801XY15 Opioids and opioid analogs; 1 to 2
801XY19 Amphetamines; 3 to 4 801XY5 Benzodiazepines; 1-12 801XY16 Opioids and opioid analogs; 3 to 4
801XY20 Amphetamines; 5 or more 801XY6 Benzodiazepines; 13 or more 801XY17 Opioids and opioid analogs; 5 or more
801XY44A Anabolic steroids; 1 to 2 801XY12 Buprenorphine 801XY8 Oxycodone
801XY44B Anabolic steroids; 3 or more 801XY37 Cannabinoids, natural 801XY21 Phencyclidine
801XY28 Analgesics, non-opioid; 1 to 2 801XY38 Cannabinoids, synthetic; 1 to 3 801XY13A Pregabalin
801XY29 Analgesics, non-opioid; 3 to 5 801XY39 Cannabinoids, synthetic; 4 to 6 801XY7A Propoxphene
801XY30 Analgesics, non-opioid; 6 or more 801XY40 Cannabinoids, synthetic; 7 or more 801XY7B Sedative hypnotics (non- benzodiazepines)
801XY27A Antidepressants, not otherwise specified 801XY43 Cocaine 801XY14 Skeletal muscle relaxants; 1 to 2
801XY22 Antidepressants, serotonergic class, 1 to 2 801XY45 Drugs or substances, definitive, qualitative, or quantitative, not otherwise specified; 1 to 3 801XY14A Skeletal muscle relaxants; 3 or more
801XY23 Antidepressants, serotonergic class, 3 to 5 801XY46 Drugs or substances, definitive, qualitative, or quantitative, not otherwise specified; 4 to 6 801XY17A Stereoisomer analysis, single drug class
801XY24 Antidepressants, serotonergic class, 6 or more 801XY47 Drugs or substances, definitive, qualitative, or quantitative, not otherwise specified; 7 or more 801XY41 Stimulants, synthetic
801XY25 Antidepressants, tricyclic and other cyclicals, 1 to 2 801XY13 Fentanyl 801XY42 Tapentadol
801XY26 Antidepressants, tricyclic and other cyclicals, 3 to 5 801XY13B Gabapentin, non-blood 801XY48 Tramadol
801XY27 Antidepressants, tricyclic and other cyclicals, 6 or more 801XY9 Heroin metabolite 28XXX13 Digoxin; free
801CY34 Antiepileptics, not other-wise specified; 1 to 3 801XY9A Katamine and norketamine 80XXX11 Valproic acid (dipropylacetic acid); free
801XY35 Antiepileptics, not otherwise specified; 4 to 6

Associated Data

paul-keoppel

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