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Is it PC only or PC + TC if a pathologist is doing all the grossing?
Grossing is part of the professional component of the test, btw.Is it PC only or PC + TC if a pathologist is doing all the grossing?
Grossing is part of the professional component of the test, btw.
A paths RVU calculation should never include TC, the only exception is frozen sections that you are performing them with no support, i.e - cutting and staining your self. In that case you can make a argument for a piece of the TC for the frozen bill to go into your RVU total (and you should go after these RVUs if your comp is based on RVU count).
I would agree that accessioning, courier costs, cost related to operations management are grey zone but in my view grossing is clearly within the PC part of the bill. Delegating grossing is certainly OK and becoming the industry norm so the pathologist can sign out more cases / day. This is important for employed paths when negotiating salary and necessary support. A hospital admin or employer could fairly point out that a part of PC collections for an employed path group be allocated to pay for Path assistant or gross room tech time for their time spent grossing. Both sides benefit from delegating grossing -- paths bill much more and are happier working outside of the grossing room, path employer has more revenue to compensate said path group..This is where the actual words of CMS matter.
If the grossing is not performed by a physician, then grossing is not part of the -26 professional component compensation. This is literally of matter of indisputable fact correct?
(quote: Professional component surgical pathology services include the gross and microscopic examination of organ tissue performed by a physician from medicare guidance on this subject)
The argument then follows if grossing can be done by a non-physician with "supervision" by a pathologist then a pathologist grossing is NOT sine qua non to be able to bill for the full professional component, correct?
So if I choose to gross as a physician, I cannot bill any additional fee to payors yes...but I choose not to gross and therefore I win.
See this is where people are getting bamboozled. Grossing by physicians was included in the medicare -26 modifier to prevent devious pathologists from billing an additional amount or even an additional TC code for a case they gross, but no where in the actual medicare guidance does it say or even imply that the amount paid out for the -26 de facto includes all the pre-processing steps like accessioning, grossing etc.
There is no specific duty list with check boxes to say this is part is the TC vs. this is part of the PC aside from the clear separation of reading the slide and rendering a diagnosis vs. cutting the actual paraffin block. Everything else is greyzone folks, dont let pathology groups or hospitals bullsh-t you.
Grossing is part of the PC.
LA - I am not saying that grossing has to be done by the path, or even should be but rather that when the global is split into the TC and PC component that grossing in the view of most stakeholders falls into the PC part of the test.https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads/R2714CP.pdf
dig through that bad boy as your reference. Find me something, otherwise literally 'what the PC is what a pathologist does'. There is nothing to actually dictate what a pathologist must do, only what he can do.
you should advocate for yourself and point out that RVU targets and published RVU data is largely composed of paths who dont gross and this is not a fair comparison in your case.