It is my understanding that pathologists cannot bill for the technical component unless:

1.   the frozen is performed in a laboratory owned and operated (meaning the technicians work for the pathologists) by the pathologists or

2.  the pathologists contract (purchased service) with the hospital to do the Part A billing (technical) and then reimburse the hospital a predetermined amount per procedure.

Please note that "global" reimbursements are often less than the total of the individual Part A and Part B reimbursements.  Also, reimbursements provided to outpatient laboratories are often less than those given to hospitals.

RWC