CMS to Finalize Proposed Physician Fee Schedule Rule by Nov. 27; CAP Expects Cuts to Some Key Pathology Codes; Other Key Payment Decisions

CAP expects the final 2014 rule to include cuts to the following pathology code families:

• Immunohistochemistry – 88342 (PC & TC)
• Enhanced Cytology Services – 88112 (PC & TC)
• In situ Hybridization – 88365, 88367, and 88368 (PC & TC)

CMS also requested additional information on the payment level for 88305 TC. CMS reduced payment for 88305 TC by 52 percent last year. The College has provided additional information to CMS on the valuation of the technical component and has argued that the TC was reduced too steeply in 2013 and did not include some key input costs.

CMS has expanded its “misvalued code” initiative by targeting the top expenditure codes from each specialty as potentially overvalued, which triggered the review of the three additional code families.

As regular readers of this newsletter know, CAP has strongly opposed the CMS proposal to link payment for 39 pathology services to the Hospital Outpatient Rates and the additional proposal to “bundle” pathology and laboratory services into the Hospital Outpatient Payment Rates. Since July 8, 2013, CAP has vigorously advocated for the withdrawal of these policy proposals through multiple channels, including comment letters to CMS and member visits to Capitol Hill and the White House.

At the same time, the CAP has also been working through the AMA Relative Value Update Committee to mitigate the payment reductions to specific pathology services by ensuring that the revaluations of pathology services accurately account for the cost of delivering the service. Nevertheless, some reductions are inevitable, particularly to some services, which may not have been revalued for many years.

As the clock ticks down, and as we wait for publication of the proposed rule, CAP’s policy team will continue to keep members updated on any new developments.

Source: CAP Statline (November 7, 2013)