BCC & SCC Mimickers: Histologic Pitfalls for Mohs Surgeons
Accurate intraoperative histologic interpretation is the cornerstone of Mohs micrographic surgery. Benign adnexal tumors (trichoepithelioma, trichoblastoma, basaloid follicular hamartoma) can closely mimic basal cell carcinoma, while reactive proliferations (pseudoepitheliomatous hyperplasia, irritated seborrheic keratosis) and keratoacanthoma can be indistinguishable from squamous cell carcinoma on frozen sections. Misinterpretation in either direction carries significant consequences: overcalling a benign mimicker as carcinoma leads to unnecessary tissue removal, while undercalling true carcinoma leaves residual tumor. This article provides a systematic approach to the most common BCC and SCC mimickers encountered during Mohs surgery, with detailed immunohistochemical panels, comparison tables, and practical decision algorithms for the Mohs surgeon.
By Dr. Yehonatan Kaplan (M.D., Fellow ACMS)·Published: 2025-03-01·Updated: 2026-03-07·Reviewed: 2026-03-07
The Mohs surgeon serves simultaneously as surgeon and pathologist, interpreting frozen sections in real time to guide complete tumor extirpation with maximal tissue conservation. This dual role demands not only the ability to identify carcinoma but also the ability to confidently exclude benign and reactive processes that may closely resemble malignancy. Tumor mimickers represent one of the most challenging aspects of Mohs histopathology, and their misinterpretation has direct clinical consequences. Overcalling a benign adnexal tumor (such as trichoepithelioma or trichoblastoma) as BCC leads to additional unnecessary Mohs stages, removal of normal tissue, larger defects, more complex reconstructions, and potential functional compromise, particularly in cosmetically and functionally sensitive areas such as the nose, eyelids, and lips. Undercalling residual carcinoma as a benign mimicker results in incomplete tumor clearance, leading to local recurrence that may require re-excision with even larger tissue loss. The frozen section environment amplifies these diagnostic challenges: tissue processing artifacts (freeze artifact, crush artifact, tangential sectioning) degrade histologic detail compared to permanent sections, and the surgeon is under time pressure to render a diagnosis while the patient waits under anesthesia.
Common Scenarios During Mohs
Several clinical scenarios during Mohs surgery raise the specter of mimickers. First, when a debulk specimen or initial Mohs layer shows basaloid nests in the deep dermis or subcutis, the surgeon must determine whether these represent BCC extending deeply or a pre-existing follicular tumor (trichoepithelioma, trichoblastoma) that was adjacent to or underlying the carcinoma. Second, when treating a biopsy-proven BCC, a subsequent Mohs layer may show benign follicular structures at the margin that must not be confused with residual tumor. Hair follicle bulbs, follicular bulge stem cells, and trichoepitheliomatous changes in follicular structures can all mimic BCC. Third, when treating SCC, the surgeon may encounter pseudoepitheliomatous hyperplasia (PEH) at the wound periphery that is reactive to the surgical procedure, chronic inflammation, or an underlying granular cell tumor. Fourth, a keratoacanthoma (KA) encountered during Mohs presents a fundamental diagnostic dilemma: is this a benign self-resolving process or a KA-type SCC that requires complete excision? Fifth, irritated seborrheic keratoses at the wound periphery can display squamous eddies and cytologic atypia that closely mimic well-differentiated SCC.
Consequences of Misinterpretation
The consequences of misinterpretation are not symmetrical. Overcalling benign mimickers as carcinoma is by far the more common error in practice, partly because the Mohs surgeon is appropriately biased toward ensuring complete tumor removal. However, systematic overcalling leads to larger-than-necessary defects, increased operative time, patient morbidity, and elevated healthcare costs. In a busy Mohs practice, understanding the histologic features that reliably distinguish mimickers from true carcinoma saves significant tissue over the course of a career. Undercalling true carcinoma, while less common, is more dangerous. A false-negative margin assessment leaves residual tumor that will recur. When uncertain, the Mohs surgeon should consider obtaining rush permanent sections, immunohistochemical stains (which can be performed on frozen section tissue), or consultation with a dermatopathologist before proceeding with additional stages.
Trichoepithelioma is the most clinically significant BCC mimicker encountered during Mohs surgery. It is a benign follicular hamartoma/neoplasm composed of basaloid cells with follicular differentiation, arising most commonly on the central face. The same anatomic region where BCCs are most frequent. Trichoepitheliomas present clinically as skin-colored to pink papules, typically 2-8 mm in diameter, and can be solitary or multiple (the latter seen in Brooke-Spiegler syndrome and familial trichoepithelioma syndromes, caused by mutations in CYLD). Histologically, trichoepithelioma shows basaloid islands with peripheral palisading and a characteristic fibrotic stroma. Features that overlap significantly with nodular BCC. However, several key features help distinguish trichoepithelioma from BCC: trichoepitheliomas typically show horn cysts (small keratinous cysts with abrupt keratinization), papillary mesenchymal bodies (small clusters of fibroblasts surrounded by basaloid cells resembling follicular papillae), CK20-positive Merkel cells scattered within the tumor periphery, and absent or very rare mitotic figures. The stroma in trichoepithelioma is characteristically fibrotic and often shows a lamellar pattern, whereas BCC stroma is typically myxoid or mucin-rich. Retraction artifact. The characteristic separation of tumor islands from surrounding stroma. Is much more prominent in BCC than trichoepithelioma.
Feature
BCC
Trichoepithelioma
Horn cysts
Absent
Present (diagnostic feature)
Papillary mesenchymal bodies
Absent
Present (follicular papilla recapitulation)
Retraction artifact (clefting)
Prominent
Absent or minimal
Stroma quality
Myxoid, mucinous
Dense, fibrotic, lamellar
Mitotic figures
Frequent
Rare or absent
Apoptotic bodies
Present
Absent
Ulceration
Common
Rare
Epidermal connection
Common (especially superficial BCC)
Rare (dermal tumor)
BerEP4
Positive (strong, diffuse)
Negative or weak/focal
CK20 (Merkel cells)
Absent within/around tumor
Present at tumor periphery
BCL-2
Diffuse (all tumor cells)
Peripheral cells only
CD10
Tumor cells positive
Stroma positive, tumor cells negative
Androgen receptor (AR)
Positive
Negative
Histologic Differentiation: BCC vs Trichoepithelioma
On frozen sections, several histologic clues favor trichoepithelioma over BCC. Horn cysts are the single most reliable feature. These small, sharply demarcated keratinous cysts represent attempted follicular differentiation and are virtually absent in BCC. Papillary mesenchymal bodies. Condensations of fibroblasts surrounded by a mantle of basaloid cells. Recapitulate the hair follicle papilla and are specific to follicular tumors. The stromal quality differs: trichoepithelioma has a densely fibrotic, eosinophilic stroma, while BCC typically shows a loose, myxoid, or mucinous stroma. Tumor-stromal clefting (retraction artifact) is a hallmark of BCC and is significantly less prominent in trichoepithelioma. Trichoepithelioma lacks the nuclear crowding, high mitotic rate, apoptotic bodies, and stromal mucin deposition that characterize BCC. Connection to the overlying epidermis is more common in BCC (particularly superficial BCC), while trichoepitheliomas are typically dermal tumors without epidermal connection. Ulceration is common in BCC and rare in trichoepithelioma.
Immunohistochemistry Panel
When frozen section morphology alone is insufficient, immunohistochemistry (IHC) provides powerful discriminatory tools. The most useful panel for the BCC vs trichoepithelioma distinction includes BerEP4, CK20, BCL-2, CD10, and androgen receptor (AR). BerEP4 (epithelial cell adhesion molecule) is positive in BCC (strong, diffuse staining) and typically negative or weakly/focally positive in trichoepithelioma. This is the single most useful stain for this distinction. CK20 highlights Merkel cells: in trichoepithelioma, CK20-positive Merkel cells are present within and at the periphery of tumor nests (mimicking the Merkel cell pattern in normal hair follicles), while BCC characteristically lacks CK20-positive Merkel cells within or around tumor nests. BCL-2 shows diffuse staining throughout the tumor islands in BCC (both peripheral and central cells), while trichoepithelioma shows BCL-2 positivity limited to the peripheral (outermost) cell layer only, similar to the pattern in normal hair follicles. CD10 shows a strikingly different pattern: in BCC, CD10 stains the tumor cells themselves, while in trichoepithelioma, CD10 stains the surrounding stroma (peritumoral stroma) but not the tumor cells. A reversal of the BCC pattern. Androgen receptor (AR) is positive in BCC and negative in trichoepithelioma, reflecting the non-follicular origin of BCC despite its basaloid morphology.
Desmoplastic Trichoepithelioma vs Morpheaform BCC
Desmoplastic trichoepithelioma (DTE) versus morpheaform (sclerosing) BCC is one of the most challenging diagnostic distinctions in all of dermatopathology, and it is particularly treacherous on frozen sections. Both present as firm, indurated, skin-colored papules or plaques on the face, most commonly on the cheek, chin, or upper lip. Histologically, both show thin cords and strands of basaloid cells embedded in a dense, sclerotic stroma. The architectural pattern that defines the desmoplastic/morpheaform spectrum. Key features favoring DTE include horn cysts (even small, rare ones are diagnostic), calcification within or adjacent to the tumor nests, a well-circumscribed deep margin (DTE tends to be superficial and well-bounded, while morpheaform BCC infiltrates deeply), absence of tumor-stromal clefting, and the presence of CK20-positive Merkel cells. Features favoring morpheaform BCC include deep invasion beyond the mid-reticular dermis, tumor-stromal clefting, connection to the overlying epidermis, perineural invasion, asymmetric growth pattern, and high mitotic rate. When uncertain, the IHC panel (BerEP4, CK20, AR, BCL-2) is invaluable. However, it must be acknowledged that even with IHC, some cases remain indeterminate, and rush permanent sections or expert dermatopathology consultation may be required.
Trichoblastoma
Trichoblastoma is a benign follicular neoplasm that presents a significant diagnostic challenge during Mohs surgery due to its basaloid cytomorphology and often large, deeply extending architecture. Trichoblastomas are generally larger than trichoepitheliomas and extend more deeply into the dermis and subcutis, often reaching 1-3 cm in diameter. They most commonly present on the face and scalp as solitary, flesh-colored to blue-gray dermal or subcutaneous nodules. Histologically, trichoblastoma is composed of basaloid cells arranged in large nodular aggregates, cribriform patterns, or racemiform (branching cord-like) configurations. Like trichoepithelioma, trichoblastoma represents follicular germinative differentiation and shows many features of hair follicle development. Papillary mesenchymal bodies, follicular bulb-like structures, and a characteristic fibroblastic stroma distinct from the mucinous stroma of BCC. Trichoblastoma was historically classified as a subtype of trichoepithelioma, but it is now recognized as a distinct entity in the WHO classification of skin tumors. The clinical significance in Mohs surgery is considerable: a large, deeply extending basaloid tumor on the face can be mistaken for nodular or nodular-infiltrative BCC, leading to extensive and unnecessary surgery if the surgeon does not recognize the follicular nature of the lesion.
Feature
Nodular BCC
Trichoblastoma
Size
Variable (usually <2 cm)
Often larger (1-3 cm)
Depth
Variable
Often deep (subcutis)
Stroma
Myxoid/mucinous
Fibroblastic (follicular-type), cellular
Papillary mesenchymal bodies
Absent
Present
CK20+ Merkel cells
Absent
Present at tumor periphery
Retraction artifact
Prominent
Minimal or absent
Deep margin contour
Irregular/infiltrative
Smooth, well-circumscribed
Mitotic rate
Moderate to high
Low
BerEP4
Positive (diffuse)
Negative or focal
BCL-2
Diffuse
Peripheral only
Distinguishing Trichoblastoma from Nodular BCC
Several histologic features reliably distinguish trichoblastoma from nodular BCC. The stroma is the most important clue: trichoblastoma has a characteristic fibroblastic (follicular-type) stroma that is cellular and eosinophilic, contrasting with the myxoid, mucinous, or hyalinized stroma of BCC. Papillary mesenchymal bodies. Compact aggregates of fibroblasts surrounded by basaloid cells, recapitulating follicular papillae. Are present in trichoblastoma and absent in BCC. CK20-positive Merkel cells are scattered throughout the tumor and at the tumor periphery in trichoblastoma, similar to the Merkel cell distribution in the normal hair follicle outer root sheath; BCC characteristically lacks CK20-positive Merkel cells. Retraction artifact is much less prominent in trichoblastoma than in BCC. Trichoblastoma typically has a smooth, well-circumscribed deep border (even when large and deep), whereas large BCCs more often show an irregular, infiltrative deep margin. Mitotic activity is generally low in trichoblastoma. The peripheral palisading in trichoblastoma is more organized and less crowded than in BCC, and the cells are generally more uniform without the marked nuclear pleomorphism seen in some BCCs.
Clinical Significance in Mohs
The encounter with trichoblastoma during Mohs is an important clinical scenario. A pre-existing trichoblastoma may be present in the surgical field as an incidental finding adjacent to or underlying a biopsy-proven BCC. The Mohs surgeon must recognize that these basaloid nests are not residual carcinoma. Alternatively, a trichoblastoma may have been misdiagnosed as BCC on the initial biopsy, leading to an unnecessary Mohs procedure. In the rare but well-described scenario of malignant transformation, trichoblastoma can give rise to trichoblastic carcinoma (previously called trichoblastic carcinomyoepithelioma or malignant trichoblastoma), which does require complete excision. If trichoblastoma is identified confidently during Mohs (based on morphology and confirmed with IHC if needed), the surgeon should stop the Mohs procedure and manage the trichoblastoma conservatively. Simple excision with narrow margins is sufficient for these benign tumors. There is no role for Mohs micrographic surgery for a benign trichoblastoma.
Other BCC Mimickers
Beyond trichoepithelioma and trichoblastoma, several other benign lesions can mimic BCC on frozen sections during Mohs surgery. While individually less common than trichoepithelioma, their collective frequency makes awareness essential. These mimickers share one common feature: basaloid cytomorphology or follicular architecture that can be confused with BCC, particularly on suboptimal frozen section preparations where tissue artifact degrades histologic detail.
Mimicker
Key Distinguishing Feature
BerEP4
CK20 Merkel Cells
Basaloid follicular hamartoma
Thin anastomosing basaloid strands with infundibular connection
Negative
May be present
Folliculosebaceous cystic hamartoma
Sebaceous lobules + fat + mesenchymal elements + cystic component
Negative
Variable
Trichofolliculoma
Central dilated pore with radiating secondary follicles
Mature sebocytes with foamy cytoplasm around central duct
Negative
N/A
Basaloid Follicular Hamartoma
Basaloid follicular hamartoma (BFH) is a benign hamartomatous proliferation of basaloid cells with follicular differentiation. It presents as small, flesh-colored papules, often multiple and concentrated on the face. Histologically, BFH shows anastomosing strands and cords of basaloid cells emanating from the epidermis and extending into the superficial dermis, surrounded by a dense, fibrous stroma. The basaloid strands are typically thin (1-3 cells thick), organized, and connected to the overlying epidermis. Creating an infundibular pattern. Key distinguishing features from BCC include the absence of retraction artifact, the presence of small horn cysts or rudimentary follicular structures within the basaloid strands, minimal cytologic atypia, absent or rare mitotic figures, and the overall symmetry and organized architecture of the lesion. BFH can be generalized (associated with systemic conditions including alopecia, myasthenia gravis, and SLE) or localized. When encountered during Mohs, BFH should be recognized as a benign hamartoma that does not require further excision.
Folliculosebaceous Cystic Hamartoma
Folliculosebaceous cystic hamartoma (FSCH) is a benign hamartoma that presents as a solitary papule or nodule on the face or scalp, typically on the nose or central face. Histologically, it shows a complex admixture of infundibular cystic structures, sebaceous lobules, mesenchymal components (including fat, smooth muscle, and fibrous tissue), and basaloid epithelial strands with follicular differentiation. The basaloid component of FSCH can mimic BCC, particularly when the sebaceous and mesenchymal components are not sampled in a given frozen section level. The presence of mature sebaceous lobules, fat, and the overall hamartomatous (disorganized but non-neoplastic) architecture distinguish FSCH from BCC. FSCH lacks retraction artifact, mitotic activity, and cytologic atypia.
Trichofolliculoma
Trichofolliculoma is a benign follicular hamartoma characterized by a central dilated follicular pore from which multiple vellus-like secondary follicles radiate outward into the surrounding dermis. It presents as a small (2-5 mm), flesh-colored papule with a central pore, most commonly on the nose. Histologically, the radiating secondary follicles can appear as basaloid epithelial strands extending into the dermis, potentially mimicking BCC nests on frozen sections. The key diagnostic clue is the central cystic structure and the organized radiating pattern of the secondary follicles. Trichofolliculoma has well-differentiated follicular structures with outer root sheath keratinization, is well-circumscribed, and lacks the cytologic atypia and mitotic activity of BCC.
Fibrous Papule (Angiofibroma)
Fibrous papule of the face (angiofibroma) is an extremely common benign lesion of the nose and central face, presenting as a dome-shaped, firm, skin-colored to pink papule typically 2-5 mm in diameter. While fibrous papule is easily recognized clinically and histologically in most cases, it can occasionally cause confusion during Mohs when its stellate fibroblasts and perifollicular fibrosis are encountered at the margin of a BCC excision. The key histologic features are a dome-shaped papule with a dermal proliferation of plump, stellate, and multinucleated fibroblasts, dilated thin-walled blood vessels, and concentrically arranged collagen bundles. Some fibrous papules show perifollicular fibrosis with basaloid follicular buds that can mimic BCC. Fibrous papules lack the nuclear palisading, retraction artifact, and cytologic atypia of BCC. BerEP4 is negative in fibrous papules. Factor XIIIa is positive in the stellate cells of fibrous papule, which can help confirm the diagnosis.
Sebaceous Hyperplasia
Sebaceous hyperplasia is an extremely common benign condition presenting as yellowish, umbilicated papules on the face of middle-aged and older adults. While clinically it is more often confused with nodular BCC (both can present as small pearly papules on the face), histologically it is usually straightforward: enlarged sebaceous lobules arranged around a central, slightly dilated sebaceous duct. However, on tangential frozen sections, the undifferentiated basaloid germinative cells at the periphery of sebaceous lobules can resemble basaloid tumor nests of BCC. The key feature is the presence of mature sebocytes (cells with foamy, lipidized cytoplasm and scalloped nuclei) maturing centripetally within each lobule. The clinical significance is primarily in avoiding misidentification of the basaloid germinative layer as BCC at the Mohs margin.
Keratoacanthoma (KA)
Keratoacanthoma (KA) is the most important and controversial SCC mimicker in dermatologic surgery. The fundamental question. Whether KA is a benign, self-resolving reactive process or a variant of well-differentiated SCC. Has been debated for decades and remains unresolved. The clinical behavior of KA is distinctive: rapid growth over 4-8 weeks to a dome-shaped, 1-3 cm nodule with a central keratotic plug, followed by spontaneous involution over 2-6 months in classic cases. However, a significant minority of KAs do not involute, and some clearly progress to invasive SCC. The concept of "KA-type SCC" has emerged as a practical framework that acknowledges the SCC-like features of many KAs while recognizing their generally favorable biology. Most Mohs surgeons treat KA as SCC, proceeding with complete excision including Mohs when indicated by location or other risk factors.
Feature
Keratoacanthoma
Well-Differentiated SCC
Growth pattern
Rapid (4-8 weeks), may involute
Gradual, progressive growth
Architecture
Symmetric, crateriform
Asymmetric, irregular
Epidermal lip
Present (overhanging shoulder)
Absent
Cytoplasm
Glassy, eosinophilic (ground-glass)
Variable, may be atypical
Deep margin
Sharp, pushing, well-demarcated
Irregular, infiltrative
Single-cell invasion
Absent
Often present
Desmoplastic stroma
Absent
May be present
Neutrophilic microabscesses
Characteristic
Uncommon
Perineural invasion
Absent
May be present (high-risk)
Cytologic atypia
Minimal
Variable, can be marked
Clinicopathologic Features
Clinically, KA presents as a rapidly growing (over 4-8 weeks), dome-shaped or crateriform nodule with a central keratotic plug. The lesion arises most commonly on sun-exposed skin of the face, forearms, and hands, predominantly in elderly, fair-skinned individuals. The rapid growth and symmetric, well-circumscribed architecture are the most distinctive clinical features. KA can occur as solitary (most common), multiple (Ferguson-Smith type, autosomal dominant), or eruptive (Grzybowski syndrome) lesions. Histologically, classic KA shows a symmetric, exo-endophytic crateriform architecture with a central keratin-filled crater. The epithelium at the shoulders of the crater overhangs the central plug, creating a characteristic lip. The squamous epithelium shows distinctive glassy, eosinophilic cytoplasm (ground-glass appearance) and is well-differentiated with orderly maturation. The deep margin is characteristically sharp and well-demarcated, pushing rather than infiltrating, with a mixed inflammatory infiltrate (neutrophils and eosinophils) at the tumor-stromal interface. Intraepithelial microabscesses of neutrophils are characteristic. Individual cell keratinization (dyskeratosis) is minimal compared to conventional SCC.
KA vs Well-Differentiated SCC
Distinguishing KA from well-differentiated SCC on biopsy and frozen sections is one of the most challenging diagnostic problems in dermatopathology. Several features favor KA: symmetric crateriform architecture, overhanging lip of normal epidermis, glassy eosinophilic cytoplasm without marked atypia, sharp deep margin, intraepithelial neutrophilic microabscesses, and absence of single-cell infiltration, desmoplastic stroma, perineural invasion, or lymphovascular invasion. Features favoring SCC include asymmetric architecture, irregular infiltrative deep margin, significant cytologic atypia, individual cell invasion (single cells or small cords infiltrating stroma), desmoplastic stromal response, perineural or lymphovascular invasion, and loss of the organized crateriform architecture. However, many lesions show overlapping features, and a small biopsy may not sample the lesion adequately to assess overall architecture. The term "well-differentiated squamous proliferation, cannot exclude SCC" or "SCC, keratoacanthoma-type" is commonly used on biopsy reports to acknowledge this diagnostic uncertainty.
Management During Mohs
The practical approach for most Mohs surgeons is to treat KA as a well-differentiated SCC and proceed with complete excision. When KA is encountered during Mohs, the crateriform architecture and pushing deep margin may be visible on frozen sections, allowing the surgeon to track the sharp tumor-stroma interface. The glassy, well-differentiated squamous epithelium of KA is generally easier to interpret on frozen sections than poorly differentiated SCC. Because KA-type tumors tend to have well-circumscribed deep margins, Mohs is often completed in a single stage. Observation alone (watchful waiting for spontaneous involution) may be considered for classic solitary KA in non-critical locations when the diagnosis is confident, the patient is informed, and close follow-up is ensured. However, observation is inappropriate for KA on the face, KA in immunosuppressed patients, KA with atypical features, or when the diagnosis of KA vs SCC is uncertain. Intralesional methotrexate (12.5-25 mg) or intralesional 5-fluorouracil can accelerate involution of KA in select cases but is not standard of care and does not provide histologic margin assessment.
Pseudoepitheliomatous Hyperplasia (PEH)
Pseudoepitheliomatous hyperplasia (PEH) is a reactive squamous epithelial proliferation that can closely mimic well-differentiated SCC on frozen sections. PEH represents an exuberant, non-neoplastic proliferation of the epidermis and follicular epithelium in response to various underlying stimuli. Chronic inflammation, infection, wound healing, or underlying neoplasm (most classically granular cell tumor). The clinical significance in Mohs surgery is considerable: PEH can appear at the peripheral margins of an SCC excision (reactive to the surgery itself or the underlying inflammatory condition) or may be the sole pathology in a lesion that was biopsied as "SCC" when the underlying cause (e.g., deep fungal infection, granular cell tumor) was not recognized. On frozen sections, the irregular downgrowth of squamous epithelium into the dermis can be virtually indistinguishable from well-differentiated SCC, making this one of the most treacherous diagnostic pitfalls for the Mohs surgeon.
Feature
PEH
Well-Differentiated SCC
Cytologic atypia
Absent (orderly maturation)
Present (nuclear pleomorphism, loss of polarity)
Single-cell infiltration
Absent
Often present
Stromal desmoplasia
Absent
Often present
Perineural invasion
Absent
May be present
Mitotic figures
Rare, basal, non-atypical
Frequent, may be atypical, suprabasal
Base of downgrowths
Rounded, bulbous
Irregular, angulated, infiltrative
Underlying cause identifiable
Often (GCT, infection, foreign body)
No (or underlying AK/in situ SCC)
Intercellular bridges
Preserved throughout
May be lost in poorly differentiated areas
Architecture
Symmetric downgrowths
Asymmetric, irregular invasion
Associated Conditions
PEH occurs in response to a wide range of underlying conditions, and recognizing these associations is the first step toward correct diagnosis. Granular cell tumor is the most classic association. PEH overlying a granular cell tumor can be so exuberant that it is mistaken for SCC on biopsy, leading to unnecessary Mohs referral. Deep fungal infections (blastomycosis, coccidioidomycosis, chromomycosis, sporotrichosis) are potent stimulators of PEH and can produce papillomatous, verrucous lesions that closely mimic SCC both clinically and histologically. Chronic wounds, ulcers, and scars (particularly chronic venous stasis ulcers, burn scars, and chronic osteomyelitis draining sinuses) develop PEH at their edges, which must be distinguished from Marjolin ulcer (SCC arising in a chronic wound). Other associations include mycobacterial infections, leishmaniasis, tattoo reactions (particularly red pigment), halogenoderma (bromoderma, iododerma), insect bites, inflammatory bowel disease (pyoderma gangrenosum), and pemphigus vegetans.
Histologic Features
PEH shows irregular downgrowths and tongues of squamous epithelium extending into the dermis, often with a jagged, interdigitating pattern. The epithelium is well-differentiated with preserved maturation, prominent intercellular bridges, and abundant eosinophilic cytoplasm. While the architectural pattern mimics SCC, several features distinguish PEH from true carcinoma. First, PEH lacks true cytologic atypia. The individual keratinocytes show normal maturation with preserved polarity, no loss of intercellular bridges, and absent or rare mitotic figures (and when present, mitoses are confined to the basal layer and are not atypical). Second, PEH does not show single-cell infiltration or small cord-like invasion. The squamous downgrowths maintain cohesive sheets and tongues. Third, PEH lacks a desmoplastic stromal response. The underlying stroma shows inflammation (often granulomatous or suppurative, depending on the cause) but not the fibrotic, desmoplastic reaction seen around invasive SCC. Fourth, perineural invasion and lymphovascular invasion are absent in PEH. Fifth, the base of PEH downgrowths tends to be rounded and bulbous rather than irregular and angulated as in invasive SCC. Importantly, the underlying cause (granular cell tumor, infectious organisms, foreign material) may be identifiable in the dermis beneath the PEH.
PEH vs SCC on Frozen Sections
Distinguishing PEH from well-differentiated SCC on frozen sections is one of the most difficult challenges in Mohs histopathology. The key diagnostic approach is systematic: First, assess the cytologic atypia. PEH shows orderly maturation with preserved polarity, while SCC shows nuclear pleomorphism, loss of polarity, and atypical mitoses. Second, look for single-cell infiltration. Isolated squamous cells or small cords of cells infiltrating between collagen bundles is diagnostic of SCC and absent in PEH. Third, assess the stromal response. Desmoplasia (dense, hyalinized, paucicellular collagen around the squamous downgrowths) strongly favors SCC. Fourth, search for perineural invasion, which is diagnostic of carcinoma. Fifth, look for an underlying cause. Granular cell tumor cells (large, polygonal cells with granular eosinophilic cytoplasm, S100-positive) or infectious organisms (yeasts, hyphae, amastigotes) beneath the PEH. When frozen section interpretation is uncertain, additional levels, PAS or GMS stains for fungi, S100 for granular cell tumor, or postponement of further Mohs stages pending rush permanent sections are appropriate strategies.
Other SCC Mimickers
Beyond keratoacanthoma and pseudoepitheliomatous hyperplasia, several additional benign and low-grade lesions can mimic SCC on frozen sections during Mohs surgery. These mimickers share the common feature of squamous proliferation. Either reactive or neoplastic. Without true invasive malignant behavior.
Mimicker
Key Distinguishing Feature
Most Helpful Ancillary Test
Inverted follicular keratosis
Squamous eddies, bland cytology, endophytic lobular growth
Koilocytes, papillomatosis, columns of parakeratosis
HPV ISH if uncertain
Prurigo nodularis
Compact orthokeratosis, neural hyperplasia, no atypia
S100 (neural hyperplasia)
Inverted Follicular Keratosis (IFK)
Inverted follicular keratosis (IFK) is a benign follicular neoplasm (currently considered by most authorities to be an irritated isthmus-type trichilemmoma or an irritated follicular infundibular keratosis) that can mimic SCC. IFK presents as a solitary, small (3-8 mm) papule or nodule on the face, often on the upper lip, nose, or cheek. Histologically, it shows an endophytic (inverted) lobular squamous proliferation arising from the epidermis and extending into the dermis. The key diagnostic feature is the presence of squamous eddies. Concentric whorls of squamous cells without a central keratinous core, representing abortive follicular keratinization. The epithelium shows bland cytology with minimal atypia. IFK can be confused with SCC because of its invasive-appearing architecture and occasional cytologic irregularity. The squamous eddies and overall bland cytology distinguish IFK from SCC. IFK is benign and does not require further excision beyond diagnostic biopsy.
Irritated Seborrheic Keratosis
Irritated seborrheic keratosis (SK) is one of the most common lesions that can mimic SCC, both clinically and histologically. When a seborrheic keratosis becomes inflamed, traumatized, or irritated, it develops squamous eddies (identical to those in IFK), increased mitotic activity, and inflammatory infiltrate. Features that can mimic SCC. On frozen sections during Mohs, an irritated SK at the margin of an excision can cause significant diagnostic confusion. Key features that distinguish irritated SK from SCC include the presence of horn pseudocysts (laminated keratin within the acanthotic epithelium), the overall flat base of the lesion (SKs sit "on top of" the skin rather than invading), hyperkeratosis and papillomatosis, and the squamous eddies themselves (which are characteristic of irritation, not malignancy). Cytologic atypia in an irritated SK is typically mild and reactive in nature, without the nuclear pleomorphism and loss of maturation seen in SCC. However, some irritated SKs can show sufficiently atypical features that distinction from SCC is impossible on frozen sections. In these cases, permanent sections should be obtained.
Clear Cell Acanthoma (Degos Acanthoma)
Clear cell acanthoma is a benign epidermal neoplasm presenting as a solitary, well-circumscribed, moist, pink-red papule or plaque, typically 1-2 cm, most commonly on the lower extremities. Histologically, it shows a sharply demarcated zone of psoriasiform acanthosis composed of keratinocytes with abundant pale, glycogen-rich cytoplasm (PAS-positive, diastase-sensitive). The sharp lateral demarcation between the clear tumor cells and adjacent normal epidermis is a diagnostic hallmark. Clear cell acanthoma can mimic SCC due to its acanthotic proliferative pattern, but the absence of cytologic atypia, the glycogen-rich pale cytoplasm, the psoriasiform architecture with neutrophilic exocytosis, and the sharp lateral boundary distinguish it from carcinoma. Clear cell acanthoma is benign and does not require excision beyond diagnostic biopsy.
Verruca Vulgaris (Common Wart)
Verruca vulgaris is caused by human papillomavirus (HPV) infection and presents as a papillomatous, hyperkeratotic papule. While clinically recognizable in most cases, verrucae can occasionally cause confusion during Mohs surgery, particularly when encountered at the margin of an SCC excision on a chronically sun-damaged hand or digit. Histologically, verruca shows papillomatous acanthosis with koilocytes (enlarged keratinocytes with perinuclear halos and wrinkled, hyperchromatic nuclei) in the upper spinous and granular layers, columns of parakeratosis overlying the papillomatous projections, and hypergranulosis. The koilocytes are the most important diagnostic feature distinguishing verruca from SCC. They are a cytopathic effect of HPV and not a feature of SCC. However, verruca and SCC can coexist (HPV is a risk factor for SCC), and some verrucous carcinomas (a SCC subtype) can be extremely difficult to distinguish from a large verruca.
Prurigo Nodularis
Prurigo nodularis (PN) presents as a firm, hyperkeratotic, dome-shaped nodule that can clinically mimic SCC, particularly in chronically sun-damaged skin. Histologically, PN shows irregular epidermal hyperplasia that can resemble PEH, with thick, irregular rete ridges extending into the dermis. However, PN shows characteristic compact orthokeratosis, hypergranulosis, and irregular acanthosis without cytologic atypia. The dermis shows perivascular fibrosis, increased dermal nerves (neural hyperplasia), and a variable inflammatory infiltrate. The absence of cytologic atypia and single-cell invasion distinguishes PN from SCC. The clinical context (intensely pruritic nodule, often on extremities, patient with history of chronic pruritus) is an important diagnostic aid. PN is not typically encountered during Mohs for SCC, but it can be clinically misdiagnosed as SCC, leading to an unnecessary Mohs referral.
IHC Decision Algorithm for Mimickers
Immunohistochemistry (IHC) is an invaluable adjunct to frozen section interpretation when morphology alone is insufficient to distinguish a mimicker from true carcinoma. In a well-equipped Mohs laboratory, IHC can be performed on frozen section tissue with results available within 30-60 minutes, allowing real-time diagnostic decision-making during surgery. The key to effective IHC use is selecting the right panel for the right clinical question and interpreting results in context. No single stain is 100% sensitive or specific, and a panel-based approach is always preferred. The decision to request IHC should be made early during the procedure when doubt first arises, as the 30-60 minute processing time can be utilized for patient care or other cases rather than causing prolonged delays.
For basaloid proliferations at the Mohs margin where the differential diagnosis includes BCC versus follicular tumor (trichoepithelioma, trichoblastoma, basaloid follicular hamartoma), the recommended first-line panel is BerEP4 and CK20. BerEP4 is the single most useful stain: strong diffuse positivity strongly supports BCC, while negativity argues against BCC and favors a follicular tumor. CK20 highlights Merkel cells: the presence of CK20-positive Merkel cells within or at the periphery of the basaloid nests favors a follicular tumor (trichoepithelioma, trichoblastoma), while their absence favors BCC. If the first-line panel is equivocal, second-line stains include BCL-2 (diffuse in BCC, peripheral-only in follicular tumors), CD10 (tumor cells in BCC, stroma in follicular tumors), and androgen receptor (positive in BCC, negative in follicular tumors). For the specific question of desmoplastic trichoepithelioma versus morpheaform BCC, the full panel (BerEP4, CK20, BCL-2, CD10, AR) may be needed, and even then, some cases remain indeterminate.
SCC Mimicker Panel
For squamous proliferations where the differential includes SCC versus reactive/benign processes (PEH, irritated SK, KA), IHC is generally less useful than for BCC mimickers, because both SCC and its mimickers express squamous markers (p63, p40, CK5/6). However, several stains can provide supportive information. Ki-67 (MIB-1) proliferation index may show higher proliferative activity in SCC (especially suprabasal staining) compared to PEH (where proliferation is largely confined to the basal layer), though there is significant overlap. EMA (epithelial membrane antigen) may show stronger and more diffuse staining in SCC than in PEH. p53 immunostaining may show aberrant pattern (strong diffuse overexpression or complete null pattern) in SCC due to TP53 mutations, while PEH typically shows wild-type scattered positivity. However, UV-damaged background skin can also show p53 clones. For the specific question of granular cell tumor underlying PEH, S100 protein will highlight the large, granular tumor cells in the dermis. For suspected deep fungal infection underlying PEH, PAS and GMS special stains are more useful than IHC.
When to Request Rush Permanent Sections
Despite the best efforts at frozen section interpretation and IHC, some cases remain genuinely indeterminate. In these situations, the Mohs surgeon should not continue to take additional stages based on an uncertain diagnosis. Instead, the appropriate action is to mark the tissue block, photograph the uncertain area on the frozen section, close the wound (temporarily if needed), and request rush permanent sections with a targeted IHC panel. Rush permanent sections can typically be available within 24-48 hours and provide superior histologic detail and more reliable IHC staining compared to frozen sections. Specific scenarios where rush permanent sections are recommended include: (1) basaloid proliferations where the BerEP4/CK20 panel is equivocal; (2) squamous proliferations where the distinction between PEH and well-differentiated SCC cannot be made on frozen sections; (3) unexpected tumor morphology that does not match the biopsy diagnosis; (4) suspected collision tumors (e.g., BCC coexisting with trichoepithelioma); and (5) any case where the surgeon is not confident in the diagnosis after reviewing all available frozen section levels and stains. The patient should be informed that the procedure is being paused pending pathology results and that a return visit may be necessary for additional Mohs stages or reconstruction.