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The rules say that plans must pay for a medical service or item if regular Medicare would pay for it in this case. 
You can find this rule at 42 Code of Federal Regulations (CFR) Section 422.101. 
 
The purpose of the NCCI PTP edits is to prevent improper payment when incorrect code combinations 
are reported. The NCCI contains one table of edits for physicians/practitioners and one table of edits for 
outpatient hospital services. The Mutually Exclusive edit file included edits where two procedures could not be 
performed at the same patient encounter because the two procedures were mutually exclusive based on 
anatomic, temporal, or gender considerations. Each edit table contains edits which are pairs of HCPCS/CPT 
codes that in general should not be reported together. Each edit has a Column One and Column Two 
HCPCS/CPT code. If a provider reports the two codes of an edit pair, the Column Two code is denied, and the 
Column One code is eligible for payment. Each NCCI PTP edit has an assigned modifier indicator. A modifier 
indicator of 1 indicates that NCCI PTP-associated modifiers may be used to bypass an edit under appropriate 
circumstances. However, an appropriate NCCI modifier was not billed with this PTP code edit. 
 
Medicare coding rules indicate the CPT code 88342 Immunohistochemistry or immunocytochemistry, per 
specimen; initial single antibody stain procedure is found under Column Two of the edit pair CPT code 88189 
Flow cytometry, interpretation; 16 or more markers found under Column One. Per Medicare Claims Processing 
Manual, Chapter 23 - Fee Schedule Administration and Coding Requirements, Section 20.9.3.1: A denial of 
services due to a Procedure-to-Procedure (PTP) edit is a coding denial, not a medical necessity denial. Most of 
these PTP edit have a modifier indicator of 1, which indicates modifiers associated with NCCI are allowed, 
however, an appropriate NCCI modifier was not billed with this PTP code edit and Column two code is denied 
as the mutually exclusive procedures cannot reasonably be performed at the same anatomic site or same 
beneficiary encounter.  
 
  
We find that the Medicare rule for payment of this claim has not been met. Physicians must report services 
correctly. This manual discusses general coding principles in Chapter I and principles more relevant to other 
specific groups of HCPCS/CPT codes in the other chapters.  
 
There are certain types of improper coding that physicians must avoid. Some codes in the "CPT Manual" are 
identified as Add-on Codes (AOCs), which describe a service that can only be reported in addition to a 
primary procedure. "CPT Manual" instructions specify the primary procedure code(s) for most AOCs. For 
other AOCs, the primary procedure code(s) is (are) not specified. When the "CPT Manual" identifies specific 
primary codes, the AOCs shall not be reported as a supplemental service for other HCPCS/CPT codes not 
listed as a primary code. In general, NCCI PTP edits do not include edits with most AOCs because edits related 
to the primary procedure(s) are adequate to prevent inappropriate payment for an add-on coded procedure (i.e., 
if an edit prevents payment of the primary procedure code, the AOC shall not be paid). An add-on code is a 
HCPCS/CPT code that describes a service that, with one exception (see CR7501 for details), is always 
performed in conjunction with another primary service. An add-on code with one exception is eligible for 
payment only if it is reported with an appropriate primary procedure performed by the same practitioner. An 
add-on code with one exception is never eligible for payment if it is the only procedure reported by a 
practitioner. Add-on codes may be identified in three ways: 
 
1. The code is listed in this CR or subsequent ones as a Type I, Type II, or Type III add-on code. 
2. On the Medicare Physician Fee Schedule Database an add-on code generally has a global surgery 
period of "ZZZ". 
 
3. In the CPT Manual an add-on code is designated by the symbol "+". The code descriptor of an add-on 
code generally includes phrases such as "each additional" or "(List separately in addition to primary 
procedure)." 
 
CMS has divided the add-on codes into three groups to distinguish the payment policy for each group. 
Type I - A Type I add-on code has a limited number of identifiable primary procedure codes. The CR 
lists the Type I add-on codes with their acceptable primary procedure codes. A Type I add-on code, with 
one exception, is eligible for payment if one of the listed primary procedure codes is also eligible for 
payment to the same practitioner for the same patient on the same date of service. Claims processing 
contractors must adopt edits to assure that Type I add-on codes are never paid unless a listed primary 
procedure code is also paid. 
 
Per Final Complete File of Add-on Code Edits for October 01, 2021 Implementation for Medicare, Type 
I  CPT Manual, HCPCS Manual, and/or CMS Policy defines all acceptable primary codes: For Add-on 
code  88341 Immunohistochemistry or immunocytochemistry, per specimen; each additional single 
antibody stain procedure (List separately in addition to code for primary procedure); appropriate Primary 
Code  88342 Immunohistochemistry or immunocytochemistry, per specimen; initial single antibody 
stain procedure. 
 
Per 2021 National Physician Fee Schedule Relative Value File Release: HCPCS 88341 Immunohistochemistry 
or immunocytochemistry, per specimen; each additional single antibody stain procedure (List separately in 
addition to code for primary procedure), Global Days  ZZZ. Field # & Item  16 Global Surgery, this field 
provides the postoperative time frames that apply to payment for each surgical procedure or another indicator 
that describes the applicability of the global concept to the service. ZZZ = Code related to another service and 
is always included in the global period of the other service. (Note: Physician work is associated with intra-
service time and in some instances the post service time.)  
 
 
 You can find these rules in the Chapter 1 General Correct Coding Policies for National Correct Coding 
Initiative Policy Manual for Medicare Services, A. Introduction, E. Modifiers and Modifier Indicators and R. 
Add-on Codes; CMS.Gov National Correct Coding Initiative Edits; CMS.Gov PTP Coding Edits; Medicare 
Claims Processing Manual, Chapter 23  Fee Schedule Administration and Coding Requirements, Section 
20.9.3.1; CMS.GOV Add-on Code Edits; Change Request 7501; Final Complete File of Add-on Code Edits for 
October 01, 2021 Implementation for Medicare, Type I  CPT Manual, HCPCS Manual, and/or CMS Policy 
defines all acceptable primary codes; 2021 National Physician Fee Schedule Relative Value File Release; 
Medicare Claims Processing Manual, Chapter 23  Fee Schedule Administration and Coding Requirements, 
50.6 - Physician Fee Schedule Payment Policy Indicator File Record Layout. 
 
If you want to read these Medicare rules, you can go to this website www.medicareappeal.com.