Comparative Billing Report webinar on CBR201407 Immunohistochemistry and Special Stains hosted by eGlobalTech and Palmetto GBA

September 12, 2014

Angela Granlund, Executive Client Administrator, Vachette Pathology

On Wednesday, August 27, 2014, CMS contractors eGlobalTech and Palmetto GBA hosted a webinar on CBR201407, a recent comparative billing report on Immunohistochemistry and Special Stains. A team from Vachette Pathology attended, including myself, and have the following to offer in summary.

Five thousand rendering pathologists, identified by National Provider Identifier (NPI), were chosen for this CBR.  Pathologists who did not receive this CBR did not meet the thresholds used to determine participation. These thresholds were not discussed or listed, however in the August G2 Compliance Advisor, the rationale given was simply because the participants’ billing patterns differed in some way from the national average of their peers.

The CBR focused on CPT codes 88305, 88312, 88313 and 88342, related specifically to esophageal and/or gastric biopsy specimens. Consultant cases were not included in this CBR.

The webinar began with a review of CPT coverage criteria: basics regarding policies of how and when to submit, medical necessity, billing protocols, etc.

The next topic covered was the methodology for determining the Average Allowed Charges per Episode of Care by CPT Code, the Average Allowed Services by CPT Code per Episode of Care, and the Percentage of Episodes with Special Stains.

  • Average Allowed Charges per Episode of Care by CPT Code:
    Determined by Total # Charges divided by Total # of Episodes for all CPT codes
  • Average Allowed Services by CPT Code per Episode of Care:

Determined by Total # Services for single CPT code divided by Total # Episodes with that CPT code

  • Percentage of Episodes with Special Stains:
    Determined using the counts of Episodes with at least one special stain

Unfortunately the webinar included no visuals, as the link to the slides was not provided until after it ended. Provider results were discussed using random examples, yet the slides could not be seen.

The provider results fell into one of four categories: Significantly Higher, Higher, Does Not Exceed or N/A.  The impression given, although not specifically stated, is that if you have codes with results that are Significantly Higher, that this is a “bad” thing.

In discussion with other attendees here in the Vachette office, we agreed this may not necessarily be so. There are at least two reasons providers may have higher results:

  • All data is related to the individual NPI, so whether the provider works for a hospital-based group or an independent lab or both does not seem to be taken into consideration for the comparison to state or national averages.
  • The results also do not seem to take into consideration if the provider works specifically with an endoscopy center and therefore may have higher results by default.

We also believe that this CBR is related to the article Palmetto GBA had on its website briefly which indicated that if you perform a high number of stains for gastric biopsies, then your practice would be looked at more closely.  We feel they will use this data to target providers for audit.

Takeaways for providers:  If you received a CBR, it is in your best interest to take the following steps:

  • Review all coding policies for IHC stains
  • Perform a coding audit on these types of cases to ensure they are indeed meeting these standards, and
  • Continue to follow eGlobalTech (the CMS contractor) for any future lab-related reports

A recording of the webinar is available for download at the link below, along with additional data on this CBR:

Webinar Recording:

CBR website:


Statistical Debriefing:


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