College of American Pathologists




November 14, 2013
© 2013 College of American Pathologists
Special Report
CAP Expects Cuts in Final CMS Physician Fee Schedule Rule by Nov. 27, Plans Webinar on Impact

November 14, 2013—When the final CMS 2014 Physician Fee Schedule rule is released on or before Nov. 27, the CAP expects it to include payment reductions to the following pathology code families based on CMS’ initiative launched in 2012 targeting high-volume physician services as overvalued:

  • Immunohistochemistry – 88342 (PC & TC)
  • Enhanced Cytology Services – 88112 (PC & TC)

CMS also requested additional information on the payment level for 88305 TC which could also result in additional reimbursement adjustments. 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. The agency also called for review of the PC and TC or in situ hybridization services—88365, 88367, and 88368. While CAP anticipated the PC and TC changes in 2015, some reductions may begin next year.

The CAP has also been working through the AMA Relative Value Update Committee to mitigate payment reductions to the specific high-volume pathology services targeted as overvalued by ensuring that the revaluations of pathology services accurately account for the cost of delivering the services. However, the CAP expects some reductions, particularly to services which may not have been revalued for many years.

In addition to the high-volume services identified in the 2012 physician fee schedule, CAP has vigorously advocated for the withdrawal of CMS’ proposal introduced on July 8, 2013 to cap payment for 39 pathology services at the rates paid in the hospital outpatient department and the additional proposal to “bundle” pathology and laboratory services into the rates paid for primary procedures performed in the hospital outpatient setting. CAP members and staff have pursued advocacy activities such as comment letters to CMS, member visits to Capitol Hill, and meetings with the White House.

Finally, the CAP staff will be closely monitoring the following five key decisions:

  1. Use of the Hospital Outpatient payment rates as a cap on payment rates in the Medicare physician fee schedule
  2. Bundling of payments for pathology and lab services
  3. New PQRS measures and requirements to report on 9 or more measures
  4. Revaluing the Clinical Lab Fee Schedule
  5. Molecular Pathology; specifically whether CMS makes any changes to the previously announced coverage decisions or payment rates for molecular pathology services.

Register for CAP’s Members-Only Webinar to Learn How the Final Rule Impacts You

On Dec. 4, the CAP will hold an exclusive, members-only webinar featuring an in-depth discussion with CAP experts about the final rule’s outcomes and implications for pathologists.

Register for the upcoming webinar.

CAP would also like to hear from you. Submit a question for CAP experts to address during the webinar.


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