THIRD EDITION Clinical Microbiology Procedures Handbook E D l TO R l N C H I E F, Third Edition and 2007 Update Lvnne S. Garcia 4 LSG & Associates, Santa Monica, California E D I TO R I N C H I E F, Original and Second Editions Henry D. Isenberg (Deceased) ASM PRESS Washington, DC Address editorial correspondence to ASM Press, 1752 N St., N.W., Washington, DC 20036-2904, USA Send orders to ASM Press, P.O. Box 605, Hemdon, VA 20172, USA Phone: 800-546-2416; 703-661-1593 Fax: 703-661- 1501 E-mail: [email protected] Online: http://estore.asm.org Copyright 0 2010 ASM Press American Society for Microbiology 1752 N St., N.W. Washington, DC 20036-2904 Library of Congress Cataloging-in-PublicationD ata Clinical microbiology procedures handbook.-3rd ed. / editor in chief, third edition and 2007 update, Lynne S. Garcia. p. ; cm. “Editor in chief, original and second editions Henry D. Isenberg.” Includes bibliographical references and index. ISBN- 13: 978-1-55581 -527-1 ISBN- 10: 1-55581 -527-8 1. Diagnostic microbiology-Laboratory manuals. I. Garcia, Lynne Shore. 11. Isenberg, Henry D. [DNLM: 1. Microbiological Techniques-methods-Laboratory Manuals. WQ 25 C6415 20101 QR67.C555 2010 6 16.9’041 4 ~ 2 2 2010014355 10 9 8 7 6 5 4 3 2 1 All rights reserved Printed in the United States of America Preface T he third edition of the Clinical Microbiology Procedures Handbook i (CMPH) is based on the value and user requirements following the first and second editions of CMPH, the companion volume Essential Procedures for Clinical Microbiology, and the 2007 update of the second edition. Almost all of the sixteen sections of the second edition of CMPH have been revised and updated; sections that did not require extensive revision will be updated during the next cycle of changes. The purpose of the third edition of CMPH remains constant. That is to provide everyone engaged in the microbiological analysis of clinical specimens with pro- cedures that will enable them to correctly perform the appropriate tasks. CMPH remains a cookbook that provides step-by-step descriptions of the numerous pro- cedures used by workers at the bench. As with the second edition of CMPH and the 2007 update of the second edition, there is increased emphasis on molecular approaches, bioterrorism, infection control in medical facilities, and the host’s immunological responses to microbial chal- lenges. Also, continued emphasis is placed on the need to respond to governmental regulations and fiscal constraints. Highly experienced workers with many years of bench experience have written these procedures, and the format adheres to CLSI document GP02-5A (5th ed., 2006). All procedures have been reviewed extensively by section editors, the editor in chief, and the ASM Press editors. We continue to encourage the users of these documents to bring new methods of universal relevance to our attention so they can be incorporated into the next update and shared with the clinical microbiology community. Readers are reminded that naming any specific product in CMPH is not intended as an endorsement of that specific product or a suggestion to exclude other equally acceptable products. CMPH is for laboratory use only by qualified, experienced individuals or by personnel under the direct supervision of qualified, experienced individuals. Every effort has been made to ensure that the contents of this update are comprehensive, accurate, reliable, and reproducible. Not all existing microbiological protocols are included; however, the editors and authors are familiar with all commonly used protocols. As newer protocols become more widely accepted and used, they will be incorporated into future CMPH re- visions. The third edition of CMPH is available in print, on CD, and as a downloadable PDF. Lynne S. Garcia xxiii J Contents VOLUME 1 Editorial Board ix Contributors xi How To Use This Handbook xvii Abbreviations xix Preface wciii Acknowledgments xxv Reader Response Form wcvii Disclaimer mix Procedure Coding, Reimbursement, and Billing Compliance 1. O. 1 Specimen Collection, Transport, and Acceptability 2.0.1 Aerobic Bacteriology 3.0.1 Anaerobic Bacteriology 4.0.1 VOLUME 2 Antimicrobial Susceptibility Testing 5.0. I Aerobic Actinomycetes 6.0.1 Mycobacteriology and Antimycobacterial Susceptibility Testing 7.0.1 Mycology and Antifungal Susceptibility Testing 8.0.1 Parasitology 9.0.1 VOLUME 3 10 Viruses and Chlamydiae 10.0.1 11 Immunology 11. O. 1 12 Molecular Diagnostics 12.0.1 13 Epidemiologic and Infection Control Microbiology 13.0.1 14 Quality Assurance, Quality Control, Laboratory Records, and Water Quality 14.0.1 15 Biohazards and Safety 15.0.1 16 Bioterrorism 16.0.1 INDEX 1.1 vii 1 Procedure Coding, SECTION Reimbursement, and Billing Compliance Alice S. Weissfeld SECTION EDITOR: Vickie S. Baselski ASSOCIATE SECTION EDITOR: 1.1. Introduction Alice S. Weissfeld and Vickie S. Baselski ........................................... .l.1 .1 1.2. Procedure Coding, Reimbursement, and Billing Compliance Alice S. Weissfeld and Vickie S. Baselski ........................................... .1.2.1 1.0.1 1.1 Introduction When the first edition of this handbook biology laboratories is provided for back- President. Statutes form the basis for sub- was published, regulatory billing compli- ground. This may be reviewed in detail in sequent regulations that are rules estab- ance for laboratory tests was not a major the Institute of Medicine’s report Medi- lished by a federal agency in response to laboratory issue. Most hospital laborato- care Laboratory Payment Policy, Now its interpretation of a statute that it is its ries generally performed services for their and in the Future (2). The history of re- duty to enforce. A number of federal agen- own inpatients (and, occasionally, affili- imbursement and compliance begins with cies are directly or indirectly involved ated outpatients), and tests were billed ac- Title XVIII, commonly known as the So- with laboratory reimbursement and com- cording to a formula established by the cial Security Act. This act outlines the pliance. The CDC is responsible for the business office. In the setting of prospec- principles of the Medicare program, spec- scientific and quality aspects of laboratory tive payment (e.g., diagnosis-related ifying broad benefit categories, including testing under the Clinical Laboratory Im- groups), payment credit was allocated physician and hospital services. In accor- provement Act (1967) and Clinical Labo- based on a different formula. Today, how- dance with section 1862 (a)(l)(A), the ratory Improvement Amendment (CLIA) ever, microbiologists must be aware not Medicare program provides payment only (1988). The CDC is advised in this process only of the scientific basis of infectious- for diagnostic laboratory tests “that are by the Clinical Laboratory Improvement disease diagnostics but also of the costing, reasonable and necessary for the diagnosis Advisory Committee. The Food and Drug coding, billing, and reimbursement for in- or treatment of illness or injury.” It does Administration (FDA) is responsible for dividual tests for patients seen in a broad not, however, authorize payment for new product clearance and, since 2003, for spectrum of health care settings with cov- screening diagnostic services. Over the en- test complexity categorization under erage by an enormous number of health suing 35 years since Title XVIII became CLIA. Medicare regulators have histori- care plans. Jargon previously unknown in law, the interpretive determination of cally interpreted tests that are subject to the clinical laboratory, such as reflex test- whether a test meets the criteria of being FDA approval or clearance but that have ing, upcoding, downcoding, local cover- reasonable and necessary to justify pay- not obtained, such as “not reasonable or age decision (LCD), and national cover- ment by Medicare has become known as necessary” for payment purposes. The age decision (NCD), is now so extensive “medical necessity.” Most other third- FDA is assisted by its Microbiology Medi- that a glossary of common terminology is party payers have established similar pay- cal Device Advisory Committee. The included in this section (Appendix 1.1-1). ment guidelines with which the laboratory Centers for Medicare & Medicaid Ser- The goal is to be reimbursed adequately must be familiar. It is notable that both vices (CMS), previously known as the for all appropriate work performed in a Medicare and other payers may make spe- Health Care Financing Administration manner that is in compliance with all reg- cific exceptions to allow payment for (HCFA), administers the Medicare Pro- ulations. screening services (eg, coverage of Pap gram. CMS interprets statutes and regu- The issues discussed in this section are smears or prostate-specific antigen test- lations and issues these interpretations complex. In keeping with the mission of ing). In the event that a coverage policy dis- through a variety of official documents this handbook, a model compliance pro- allows payment for a service on the basis of (e.g., The Medicare Program Integrity cedure has been written. As with any pro- medical necessity, it is possible to transfer Manual [ 11, program memoranda and cedure, we expect some customization to financial liability to the patient providing transmittals, and change requests) to de- occur. The model procedure deals primar- an advanced beneficiary notice (ABN) has fine coverage criteria, establish national ily with some of the more important reg- been properly executed which informs the limitation amounts, and establish national ulatory principles. It should not, in any sit- patient of their financial responsibility. In coverage decisions (NCDs). CMS also uation, take the place of guidance 2009, a laboratory-specific ABN, CMS-R- contracts with independent insurers established by your own compliance com- 131-L, was discontinued and replaced known generically as contractors and spe- mittee or of legal advice from your own with a generic ABN, CMS-R-131. Infor- cifically as carriers (for part B outpatient institution’s legal counsel. It simply rep- mation may be accessed at http://www. services), as fiscal intermediaries (FIs; for resents a starting point for review of sa- cms.hhs.gov/BNUO2~ABN.asp. part A inpatient services or part B services lient issues. The Social Security Act is known as a through part A providers), and, more re- A brief historical overview of the eco- statute, i.e., a piece of legislation voted cently, as Medicare administrative con- nomic challenges faced by clinical micro- into law by Congress and signed by the tractors (MACs; for part A and part B ser- 1.1.1 1.1.2 Procedure Coding, Reimbursement, and Billing Compliance vices) to administer claims to reimburse for review and update was implemented in were introduced in 2002. Category I11 physicians or laboratories. CMS is advised 2003, and under the Medicare Improve- codes are generally not reimbursable. In in developing coverage policies by the ments for Patients and Providers Act of some cases, newer emerging technologies Medicare Carrier Advisory Committee 2008, CMS can now propose new NCDs may also be assigned an interim HCPCS (MCAC) and other contractor committees for preventive (screening) services. Three code. The ICD-9-CM system is a public such as technology assessment groups. In- NCDs were developed in infectious-dis- domain consensus document developed dividual carriers, Fls, and MACs may also ease diagnostics by a committee cochaired by the World Health Organization. It in- set payment policies, known as LCDs, for by the American Society for Microbiol- cludes specific diagnoses as well as signs their own geographic regions. Examples ogy: urine culture, human immunodefi- and symptoms or medical conditions that of LCDs in infectious-disease diagnostics ciency virus (HIV) diagnosis, and HIV represent the physician’s reason for order- include syphilis testing, blood cultures, monitoring and prognosis. The Negotiated ing a test. It also has a series of preventive- antimicrobial susceptibility testing, Rulemaking Committee also developed a medicine screening codes (V codes) that TORCH (Toxoplasma, rubella, cytomeg- number of administrative policies which in general do not support medical neces- alovirus, and herpes simplex virus) test- became effective in 2003. A database in- sity. It is of note that a major update, ing, and human papillomavirus testing. dex for current NCDs may be accessed at ICD-10, should be implemented by Oc- Any information on institutional billing http://www.cms.hhs.gov/transmittals/ tober 2013. Correct coding is the corner- and reimbursement should include a downloads/rl7ncd.pdf. Again, billings to stone of reimbursement and compliance. search for LCDs specific to infectious-dis- other payers may require submission of Finally, in 1997, in response to a major ease diagnostic testing. For this, a specific other specific forms, but coverage criteria antifraud and abuse campaign in the Medi- website exists at http://www.cms.hhs.gov/ are often modeled after Medicare billing care program (Operation Restore Trust), mcd/overview.asp (Appendix 1.1-2). guidelines. the Office of the Inspector General pub- Medicare generally requires that labora- Coding is the process of assigning a lished a series of compliance documents, tories submit billings electronically, but it procedure code such as a Current Proce- including one for clinical laboratories. may occasionally accept handwritten bills dural Terminology (CPT), or a diagnosis One such document, the Office of Inspec- on HCFA form 1500 for part B and HCFA or condition, code, usually the Interna- tor General’s Compliance Program Guid- for UB92 for part A, both universal insur- tional Classification of Diseases, Clinical ance for Clinical Laboratories, published ance billing forms. Payment denials may Modification (ICD-9-CM), code, for the in August 1998, contains an outline for the be appealed through a formal process and purpose of submitting a claim for reim- design of individual institutional compli- ultimately referred to an administrative bursement. CPT codes are property of the ance plans to ensure correct coding, ap- law judge. As a result of deliberations by American Medical Association but have propriate billing, and honest and ethical a Negotiated Rulemaking Committee on been named as the official CMS HCFA laboratory business practice (3). This doc- clinical laboratory diagnostic tests man- Common Procedure Coding System ument, although more than a decade old, dated by the Balanced Budget Act of (HCPCS). CPT codes are updated an- still forms the basis for laboratory billing 1997, 23 NCDs were developed which nually by a lengthy, systematic process. compliance and for the model compliance take precedence over any existing LCDs Most codes are Category I and represent plan presented in this section. for the same tests. Implementation for generally accepted procedures, but Cate- these NCDs occurred in 2002, a process gory I11 codes for emerging technologies REFERENCES 1. Centers for Medicare and Medicaid Ser- 3. Office of the Inspector General. 1998. Com- vices. 2008. Medicare Program Integrity pliance program guidance for clinical labora- Manual. Centers for Medicare and Medicaid tories. Fed. Regist. 63:45076-45087. Services, Baltimore, MD. http://www.cms. hhs.gov/rnanuals/iom/ItemDetail.asp?ItemID= CMSOl9033. 2. Institute of Medicine. 2000. Medicare Lab- oratory Payment Policy: Now and in the Fu- ture. National Academy Press, Washington, DC. Introduction 1.1.3 APPENDIX 1. l-1 Glossary of Reimbursement and Compliance Terminology and Acronyms Terminology Terminology Definition Abuse Systematically accepting improper payment without knowledge of illegality (see Fraud) Add on A test added after the original date of service Bundling Placing codes together in a panel Carrier CMS contractor for part B claims Carve out Exclude from a capitated contract and bill fee-for-service Code jamming Inserting ICD-9 codes to pass claims review Code stacking The use of two or more procedural codes to denote a single reportable test result Code steering Encouraging ICD-9 code use to satisfy medical necessity Comparative Assessment of clinical comparability of procedures that may result effectiveness in reimbursement of a new technology at the rate of an older technology Composite The use of two or more test codes simultaneously in accordance with standard of care and not otherwise described as a panel Contractor Generic term for Medicare claims administrator Covered lives Population insured by a managed-care contract Crosswalked Deemed equivalent (see Mapped) Custom panel User-defined composite of test codes performed simultaneously which is not a standard of care Downcoding Using a lower paying code to encourage utilization E codes Codes for external sources of injury Fair market value A reasonable payment amount for a specified service Fraud Knowingly or willingly accepting improper payments with knowledge of illegality (see Abuse) Frequency limits Number of times a service may be reimbursed Gap fill Temporary assignment of reimbursement Inducement Service or item with monetary value given to encourage utilization by a purchaser of laboratory services Kickback Acceptance of an inducement Mapped Deemed comparable (see Crosswalked) Medical necessity Determination of ICD-9-CM codes for which a CPT code will be reimbursed as reasonable and necessary Modifiers Two-character (numeric for CPT and alpha for HCPCS) units appended to a CPT code to indicate a condition affecting payment Neg Reg Negotiated Rulemaking Committee on diagnostic clinical laboratory tests Not medically Determination that an ICD-9 CM does not justify payment for a necessary CPT code Panel CMS-approved test composite encompassed in a single CPT code Program integrity Process by which CMS monitors for fraud and abuse Reasonable charge Based on inherent reasonableness, authority to arbitrarily increase or methodology decrease payment Reflex Second related test automatically performed when an initial test result is positive or abnormal Remittance advice Provides explanation of any adjustment made to expected payment codes for a service; includes claim adjustment reason codes and remittance advice remark codes Sink testing Fraudulently reporting results for tests not performed Standing orders Preapproved set of test codes performed on a regular defined basis Unbundling Coding individual tests rather than a single defined panel Upcoding Using a higher-paying code to maximize reimbursement V codes Generally, health screening codes Zero tolerance Absolute institutional policy that no fraudulent practice will be allowed 1.1.4 Procedure Coding, Reimbursement, and Billing Compliance APPENDIX 1. l-1 (continued) Acronyms Acronym Definition ABN Advanced beneficiary notice ALJ Administrative law judge AMA American Medical Association APC Ambulatory payment classification in the OPPS ASR Analyte-specific rule BBA '97 Balanced Budget Act of 1997 CAC Camer Advisory Committee CAP College of American Pathologists CCI Correct Coding Initiative (also known as the National Correct Coding Initiative, NCCI) CDC Centers for Disease Control and Prevention CERT Comprehensive Error Rate Testing Program CLFS Clinical laboratory fee schedule (see NLA) CLIA '67 Clinical Laboratory Improvement Act of 1967 CLIA '88 Clinical Laboratory Improvement Amendments of 1988 CLIAC Clinical Laboratory Improvement Advisory Committee CMD Contractor medical director CMS Centers for Medicare and Medicaid Services CPT Current Procedural Terminology DRG Diagnosis-related group in the IPPS EOMB Explanation of medical benefits (also explanation of benefits, EOB) ESRD End-stage renal disease (dialysis center) FBI Federal Bureau of Investigation FDA Food and Drug Administration FI Fiscal intermediary FTE Full-time equivalent HCFA Health Care Financing Administration (now CMS) HCPAC Health Care Professionals Advisory Committee HCPCS HCFA Common Procedure Coding System HIPAA Health Insurance Portability and Accountability Act ICD-9-CM International Classification of Diseases, 9th ed., Clinical Modification ICD- 10 International Classification of Diseases, 10th ed. IDE Investigational device exemption IOM Institute of Medicine IPPS Inpatient prospective payment system (see DRG) LCD Local coverage decision (previously known as LMRP) LMIP Laboratory Management Index Program LMRP Local medical review policy (now LCD) MAC Medicare administrative contractor (for A and B claims) MedPAC Medicare Payment Advisory Council MIPPA Medicare Improvement for Patients and Providers Act of 2008 MMA '03 Medicare Modernization Act of 2003 MUE Medically unlikely edit for frequency in the CCI edits NCD National coverage decision (previously known as NCP) NCP National coverage policy (now NCD) NLA National limitation amount in the CLFS NPI National provider identifier OCE Outpatient code editor (for OPPS) OIG Office of the Inspector General OPPS Outpatient prospective payment system PCC Pathology coding caucus PFS Physician fee schedule PPAC Practicing Physician Advisory Council RAC Recovery audit contractor SBT Standardized billable test SNF Skilled-nursing facility (nursing home) Introduction 1.1.5 APPENDIX 1 .I-2 Websites and Guidance Documents I. WEBSITES A. All contractor LCDs, http://www.cms.hhs.gov/mcd/overview.asp B. CMS website, http://www.cms.hhs.gov (to subscribe to regular updates, go to http:// www.cms.hhs.gov/AboutWebsite/EmailUpdates/list.asp) C. General Accounting Office, http://www.gao.gov (search “Medicare” for recent re- ports) D. FDA, http://www.fda.gov (to subscribe to regular updates, go to http://www.fda.gov/ AboutFDNContactFDNSt ayInformed/GetEmailUpdates/default.h tm) E. Health Care Compliance Association, http://www.hcca-info.org F. IOM study on Medicare Laboratory Payment Policy (http://www.iom.edu/iom/iom + home/nsf/pages/clinlab home +page) G. Medicare Clinical laboratory fee schedules, http://www.cms.hhs.gov/ClinicalLab FeeSched/02-clinlab.asp#TopOfPage H. Medicare fee schedules: general information, http://www.cms.hhs.gov/Fee ScheduleGenInfo/ I. Medicare manuals, http://www.cms.hhs.gov/Manuals/Ol-0verview.asp J. Medicare physician fee schedule, http://www.cms.hhs.govPhysicianFeeSched/ K. Medicare Learning Network, http://www.cms.hhs.gov/MLNGenInfo/ L. Medicare Payment Advisory Commission, http://www.medpac.gov M. National Center for Health Statistics for ICD-9-CM updates, http://www.cdc.gov/ nchs/icd.htm N. National Correct Coding Initiative, http://www.cms.hhs.gov/NationalCorrectCod InitEd/ 0. National Technical Information Service for published NCCI edits, http:// www.ntis.gov P. OIG website for Compliance Program, Fraud Alerts, Advisory Opinions, Red Book, Work Plan, http://oig.hhs.gov (to subscribe to regular updates, go to http:// oig.hhs.gov/mailinglist.asp) Q. Strategic Management (previously The American Compliance Institute), http:// www.strategicm.com/ II. OTHER GUIDANCE DOCUMENTS A. ABN current format and instructions, http://www.cms.hhs.govlBNY02_ABN.asp B. Guidance for industry and FDA staff--commercially distributed analyte-specific re- agents, frequently asked questions, http://www.fda.gov/MedicalDevices/Device RegulationandGuidance/GuidanceDocuments/ucmO7842.3h tm C. Medical devices: classification/reclassificationr, estricted devices, analyte-specific re- agents, Fed. Regist. 62:62243-62260 (1997) D. Medicare: HCFA faces challenges to control improper payments, T-HEHS-00-74,9 March 2000, http:/lwww.gao.gov E. Medicare Claims Review Program: NCCI edits, MUEs, CERT, and RAC, Medicare Learning Network Publication (October 2008), http://www.cms.hhs.gov/MLNProd ucts/downloads/MCRPBooklet.pdf F. Medicare clinical trials policies, http://www.cms.hhs.gov/ClinicalTrialPolicies/ G. Medicare Fraud & Abuse, Medicare Learning Network Publication (January 2009), http://www.cms.hhs.gov/MLNProducts/downloads/110107-Medicare-Fraud-and- Abuse-brochure.pdf H. Medicare program: application of inherent reasonableness to all Medicare part B services (other than physician services), Fed. Regist. 67:76684-76697 (2002) I. Medicare Program: criteria and procedures for extending coverage to certain devices and related services, Fed. Regist. 60:484 17-48425 ( 1995) J. Medicare program: establishment of procedures that permit public consultation under the existing process for making coding and payment determinations for clinical lab- oratory tests and new durable medical equipment, Fed. Regist. 66:58743-58745 (2001) K. Medicare program: negotiated rulemaking: coverage and administrative policies for clinical diagnostic laboratory services; final rule, Fed. Regist. 66:58787-58836 (2001)
Description: