2019 FNA Biopsy Changes

Leslie Bargfrede, CPC, CIRCC, RCC, RCCIR
Corporate Coding Manager – Interventional Radiology

CPT has created a new code set for Fine Needle Aspiration (FNA) for use as of January 1, 2019. A comprehensive code set has been created which now bundles the FNA to include imaging guidance, and the new codes are assigned based on modality of imaging performed (US, Fluoro, CT, MR). These codes are reported once per lesion sampled in a single session. There is one primary code for each modality of imaging and one add-on code for the same modality. A primary code is assigned for the first lesion sampled and add-on codes are applied when the same modality of imaging is used for each additional lesion sampled. This applies whether the lesions are ipsilateral or contralateral to each other or if they are in the same or different organs/structures. There are also codes for FNA performed without the use of imaging guidance which follow the above rationale for application.

With this new code set, CPT has also published extensive instructional information on the appropriate assignment of these codes. However, in some instances, this instruction differs from the instruction published by the Centers for Medicare and Medicaid Services (CMS) and the National Correct Coding Initiative (NCCI) Policy Manual. It is important to be mindful of the differences in coding and billing based on payer policy, when applicable.

CPT Instruction:

Codes 10004, 10005, 10006, 10007, 10008, 10009, 10010, 10011, 10012, 10021 are reported once per lesion sampled in a single session.

National Correct Coding Initiative (NCCI) Policy, Chapter 3 K, Medically Unlikely Edits:

The unit of service for fine needle aspiration biopsy (CPT codes 10004-10012 and 10021) is the separately identifiable lesion. If a physician performs multiple “passes” into the same lesion to obtain multiple specimens, only one unit of service may be reported. However, a separate unit of service may be reported for a separate aspiration biopsy of a distinct separately identifiable lesion. (CPT code 10022 was deleted January 1, 2019.)

CPT Instruction:

  • FNA biopsies only:
    • When more than one FNA biopsy is performed on separate lesions at the same session, same day, same imaging modality, use the appropriate imaging modality add-on code for the second and subsequent lesion(s).
    • When more than one FNA biopsy is performed on separate lesions, same session, same day, using different imaging modalities, report the corresponding primary code with modifier 59 for each additional imaging modality and corresponding add-on codes for subsequent lesions sampled.
      • This instruction applies regardless of whether the lesions are ipsilateral or contralateral to each other, and/or whether they are in the same or different organs/structures.
  • FNA with Core biopsy:
    • When both FNA biopsy and core needle biopsy are performed on the same lesion, same session, same day using the same type of imaging guidance, do not separately report the imaging guidance for the core needle biopsy.
    • When FNA biopsy is performed on one lesion and core needle biopsy is performed on a separate lesion, same session, same day using the same type of imaging guidance, both the core needle biopsy and the imaging guidance for the core needle biopsy may be reported separately with modifier 59.
    • When FNA biopsy is performed on one lesion and core needle biopsy is performed on a separate lesion, same session, same day using different types of imaging guidance, both the core needle biopsy and the imaging guidance for the core needle biopsy may be reported with modifier 59.

National Correct Coding Initiative (NCCI) Policy, Chapter 3 K, Medically Unlikely Edits:

Fine needle aspiration (FNA) biopsies (CPT codes 10004-10012, and 10021) shall not be reported with a biopsy procedure code for the same lesion. For example, an FNA specimen is usually examined for adequacy when the specimen is aspirated. If the specimen is adequate for diagnosis, it is not necessary to obtain an additional biopsy specimen. However, if the specimen is not adequate and another type of biopsy (e.g., needle, open) is subsequently performed at the same patient encounter, the physician shall report only one code, either the biopsy code or the FNA code. (CPT code 10022 was deleted January 1, 2019.)

Per the National Correct Coding Initiative (NCCI) Policy, Chapter 9 G, Medically Unlikely Edits:

CPT codes 76942, 77002, 77003, 77012, and 77021 describe radiologic guidance for needle placement by different modalities. CMS payment policy allows one unit of service for any of these codes at a single patient encounter regardless of the number of needle placements performed. The unit of service for these codes is the patient encounter, not number of lesions, number of aspirations, number of biopsies, number of injections, or number of localizations.

Most importantly for physicians is to clearly document the following information in the procedural report.

  • Physicians should clearly document:
    • The number and location(s) of lesion(s) biopsied
    • Technique used for biopsy performed (FNA, Core or both)
    • Modality and description of guidance used for each biopsy