The American Society for Clinical Pathology (ASCP) strongly supports the Centers for Medicare and Medicaid Services’ (CMS) framework for its proposed physician fee schedule (PFS) for 2008, but the Society believes it may be necessary to enhance the rules in several areas. ASCP scored a significant victory when CMS released the proposed PFS on July 12, as the Agency recommitted itself to preventing the potential for billing abuses by "pod labs" and other arrangements using contractual joint ventures that markup the cost of anatomic pathology services.
Among the areas in the proposed PFS still in need of revision are the proposed rules regarding the definition of a full-time employee of the billing physician or group practice performing the Technical Component (TC)/Professional Component (PC). ASCP seeks to ensure that the employee would be a bona fide full-time employee working exclusively for the billing entity as proposed by CMS last year. ASCP is a strong and persistent supporter of CMS’s 2006 proposal to eliminate the potential for abuse of the Medicare reassignment and self-referral provisions.
In addition to meeting directly with CMS officials and Congressman Pete Stark, Chairman of the House Ways and Means Health Subcommittee, to urge action, ASCP launched its"Stop Pod Labs Now" campaign, which generated approximately 2,000 letters to Congress asking legislators to push CMS to implement stringent reforms to block potentially abusive billing practices. Phase II of the campaign launches on August 1, 2007. For more details, watch for the August issue of ASCP’s ePolicy News, by email Aug. 1 or online at http://capwiz.com/ascpath/issues/alert/?alertid=10115991.