Coding

PGT Billing: Who Bills What and How to Avoid Lab Claim Conflicts

PGT billing involves the clinic, the embryology lab, and a third-party genetics lab — all with overlapping CPT codes. Here is how to coordinate billing and avoid duplicate claim conflicts.

EasyRCM Editorial··7 min read

Preimplantation genetic testing billing is uniquely complex because it involves three entities: the fertility clinic, the embryology lab (in-house or contracted), and the third-party genetics reference laboratory. Each bills for its portion of the service, and CPT codes used at the clinic level overlap with codes that appear on the genetics lab's claim — creating duplicate billing exposure when coordination fails.

What the Clinic Bills

The fertility clinic or its embryology lab bills for embryo biopsy — the procedural component of PGT. CPT 89290 covers embryo biopsy with fewer than 5 embryos; 89291 covers 5 or more embryos. These are the clinic-side PGT codes. The clinic also bills 89258 for embryo cryopreservation if the embryos are frozen during the PGT cycle, which is standard practice since genetic results typically take 7 to 14 days.

What the Genetics Reference Lab Bills

The third-party genetics reference lab bills for the genetic analysis — the array or sequencing component. For PGT-A (aneuploidy testing), the lab typically bills 81228 or 81229 (chromosomal microarray). For PGT-M (monogenic disease testing), billing depends on the specific assay and condition. These analysis codes should appear on the genetics lab's claim — not the clinic's. When clinics bill 81228 alongside 89290 or 89291, payers may flag the claim as duplicating the genetics lab submission.

Duplicate Billing Risk

When clinics bill genetic analysis codes (81228, 81229) that the reference lab is also billing, payers will identify the duplication during claim adjudication or post-payment audit. The result is a refund request against the clinic for the analysis codes — even when the clinic billed them in good faith.

Common PGT Billing Conflicts

  • Clinic bills 81228 or 81229 that the genetics reference lab also submits — creates duplicate claim denial or post-pay recovery.
  • Genetics reference lab is out-of-network with the patient's plan, creating an unexpected patient balance that the practice did not disclose.
  • Authorization was obtained for the biopsy (89290/89291) but not the genetic analysis — analysis claim denies as unauthorized.
  • PGT-M analysis is billed using PGT-A codes — each testing type has distinct code requirements tied to the assay methodology.
  • No coordination between clinic and genetics lab on billing responsibility when a biopsy fails or a re-biopsy is performed.

Coordinating Billing Between Clinic and Lab

  • Establish a written agreement with your reference genetics lab specifying which entity bills which CPT codes — and what happens in re-biopsy or failed-biopsy scenarios.
  • Include the genetics lab's NPI and TIN in the authorization request when payers require both the biopsy and the analysis to be authorized.
  • Obtain separate authorizations for the biopsy (clinic) and genetic analysis (reference lab) when the payer requires them.
  • Educate patients that they will receive two separate bills for a PGT cycle — one from the clinic and one from the genetics reference lab.
  • Audit PGT claims quarterly against genetics lab remittances to identify any overlap in billed codes.

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