College of American Pathologists




November 21, 2013
© 2013 College of American Pathologists
Special Report
Pathology Payment Cuts Could Be Announced Any Day by CMS; Register Now for CAP’s Webinar to Learn How the Rule Impacts You

November 21, 2013—With a final CMS 2014 Physician Fee Schedule rule expected by 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 has 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 of 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 reductions for immunohistochemistry and enhanced cytology as these services have not been revalued for many years.

These changes to high-volume services identified in the 2012 physician fee schedule are separate from this year’s proposed rule initiative. CAP has vigorously advocated for withdrawal of this initiative, which caps payment for 39 pathology services at the rates paid in the hospital outpatient department, as well as an additional proposal to “bundle” pathology and laboratory services into the rates paid for primary procedures performed in the hospital outpatient setting. In response to these proposals, 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. These proposed reductions are in addition to the anticipated changes in codes 88342 and 88112 and are still in play.

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.


202-354-7118  •  202-354-8101 (fax)  •  800-392-9994


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