College of American Pathologists




July 22, 2013
© 2013 College of American Pathologists
Special Report
CAP Calls on CMS to Further Examine Pathology Payment Methodology

July 22, 2013—The College of American Pathologists (CAP) called on the Centers for Medicare and Medicaid Services (CMS) to further examine its methodology for identifying “misvalued codes” by capping the technical component (TC) payment and resulting global payments on the physician fee schedule. CMS’ proposal would tie the fee schedule rates for services performed on non-hospital patients to the hospital outpatient payment rates. At a briefing with CMS, the agency announced that a math error led to revision of the list of impacted codes, removing CPT code 88120 (Cytopathology, in situ hybridization (eg, FISH), urinary tract specimen with morphometric analysis, 3-5 molecular probes, each specimen; manual) from the impacted list. CAP called on CMS to further examine all of the impacted codes for any additional errors.

As included the previous issues of Statline, the impact of this proposed rule would result in payment reductions to the TC and global of 39 services billed by pathologists performed on non-hospital patients. Following are updated impact charts based on this change, listing the top 10 reductions as well as those services which increase based on other payment policies in the proposed rule.

Top Ten Reductions to Pathology Services Based on Volume and Proposed Change

88307GlobalTissue exam by pathologist- 50%
88342GlobalImmunohistochemistry- 27%
88312GlobalSpecial stains group 1- 46%
88313GlobalSpecial stains group 2- 45%
88112GlobalCytopath cell enhance tech- 22%
88185GlobalFlowcytometry/tc add-on- 75%
88309GlobalTissue exam by pathologist- 30%
88173GlobalCytopath eval fna report- 25%
88367GlobalInsitu hybridization auto- 60%
88108GlobalCytopath concentrate tech- 39%

Top Ten Increases to Pathology Based on Volume and Proposed MEI Change:

88305Professional ComponentTissue exam by pathologist4%
88342Professional ComponentImmunohistochemistry5%
88305GlobalTissue exam by pathologist1%
88307Professional ComponentTissue exam by pathologist3%
88112Professional ComponentCytopath cell enhance tech4%
88331Professional ComponentPath consult intraop 1 bloc3%
88312Professional ComponentSpecial stains group 13%
88309Professional ComponentTissue exam by pathologist3%
88173Professional ComponentCytopath eval fna report3%
88313Professional ComponentSpecial stains group 25%


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