Updated February 25, 2014
The Centers for Medicare and Medicaid Services released the final 2014 Physician Fee Schedule (PFS) Rule and the Hospital Outpatient Payment Rule. CAP has provided a list of frequently asked questions to offer additional information on the ruling.
CAP Provides Members with Resources on Coding Challenges
The College of American Pathologists is strongly committed to its role as the leader in pathology CPT coding advocacy. However, CAP is not able to respond to individual CPT billing questions as we cannot assume liability for a CAP member’s decision on interpretation of the Current Procedural Terminology (CPT) codes that are defined by the American Medical Association (AMA) or the G codes that are defined by the Centers for Medicare Services (CMS). To that end, we provide you with the following sources of original information.
CAP recommends that its members obtain a copy of the American Medical Association’s (AMA) CPT Professional Codebook if they do not already have one. The CPTÂ® 2014 Professional Edition is the definitive AMA authored resource to help health care professionals correctly report and bill medical procedures and services. The AMA publishes the only CPT® codebook with the official CPT guidelines. Only the AMA, with the help of physicians and other experts in the health care community, creates and maintains the CPT code set. It is available for purchase at AMA 2014 CPT Codebook.
CAP also recommends that its members contact their individual carriers or payers on their specific payment policies.
CAP has arranged for members to receive a discount on subscriptions to a CPT coding service. Through the PathLab Coding Solutions service, subscribers receive timely written responses supported by authoritative documentation to their CPT questions. Non-CAP members may subscribe to the service at a non-discounted rate. A subscription is required to submit a question to PathLab Coding Solutions. More information on PathLab Coding Solutions is available after logging on to
in the Coding and Payment section of cap.org/practicemanagement.
CAP members should also utilize the Centers for Medicare Services (CMS) as the official source on information on G code reporting (see pg. 74333).
The College also has compiled several resources on the Medicare physician fee schedule rule. Listen to CAP’s recent webinar to learn more about how the rule impacts you. A list of frequently asked questions also is available for download.
CAP has been meeting with CMS and the White House to lay out our specific concerns. On September 6, CAP submitted formal comment letters to CMS:
CAP has also engaged with the AMA and other affected organizations to strengthen our response efforts. As the Congress considers legislation to repeal the Sustainable Growth Rate (SGR), CAP is engaged in finding alternative ways for pathologists to meet quality and pay for performance requirements.
- CAP opposes this new round of cuts to pathologists and pathology practices.
- CMS’ proposal to link payment for pathology services to rates paid in the hospital outpatient prospective payment system is particularly concerning.
- The proposed policy fails to take into consideration the technical costs associated with specific individual codes.
- Further, it fails to recognize the distinct costs of physician services, which are required by law to be based on the resources required to perform the service.
- CAP supports the existing AMA-RUC process for valuing physician service codes. This process involves many stakeholders, including CAP.
- The AMA-RUC has shown itself to be accurate and fair, and has been thoroughly vetted over many years.
- CAP remains concerned about CMS’ implementation of the Physician Quality Reporting System. CAP proposed three new quality measures for pathologists, which CMS rejected.
The 2014_Physician Fee Schedule Final Rule Impact Table
(Excel, 176 KB)
Change in APC Payment Rates for Select Pathology Services
(PDF, 110 KB)
- CAP Comments on Medicare 2014 Physician Fee Schedule Final Rule
January 27, 2014 (PDF, 143 KB)
- CMS Halts Plan to Cap Pathology Payments to APC Rates, Payment for Other Key Services is Reduced
November 27, 2013 (PDF, 40 KB)
- CMS Halts Plan to Cap Pathology Payments to APC Rates, Payment for Other Key Services Reduced
November 27, 2013
- Pathology Cuts Letter to CMS,
October 17, 2013 (PDF, 31 KB)
- Cancer Leadership Comments to CMS on Physician Fee Schedule,
September 6, 2013 (PDF, 31 KB)
- Sidley Austin Memo on Proposed Rule (CMS-1600-P),
September 4, 2013 (PDF, 394 KB)
- 40 Medical Organizations Sign-on to Letter Addressing the CMS Proposal to Cap Payment in Physician Offices at Facility Levels, August 29, 2013 (PDF, 335 KB)
- CAP Advocacy Action Alert, August 27, 2013 (PDF, 165 KB)
- After Claims Denied, CMS Revises Technical Component of
Pathology Services, August 26, 2013
- CAP Joins Other Pathology, Laboratory and Diagnostics Industry Groups In Opposing CMS Physician Fee Schedule Proposed Rule for CY 2014, August 23, 2013
(PDF, 139 KB)
- CAP Advocacy Action Alert, August 13, 2013 (PDF, 165 KB)
- CAP Advocacy Action Alert, August 6, 2013 (PDF, 153 KB)
- Issue Brief: Medicare Payment for Pathology Services, (PDF, 131 KB)
- Letter opposing the physician fee schedule cuts and asking Congress to intervene signed by major pathology organizations and state pathology societies July 31, 2013 (PDF, 18 KB)
- CAP Advocacy Action Alert, July 30, 2013 (PDF, 104 KB)
CAP Advocacy Action Alert, July 19, 2013
View the CMS 2014 Physician Fee Schedule Webinar.
A recording of the Dec. 4 CMS Physician Fee Schedule webinar is now available online. The 90-minute webinar features CAP leaders explaining the changes announced by CMS regarding the final 2014 Physician Fee Schedule (PFS) rule released on Nov. 27, which contains reimbursement changes affecting pathologists. Learn about the final rule’s pathology-related details, the impact on pathologists and CAP’s advocacy efforts around these issues. The webinar also includes a Q & A with the CAP’s staff and members.
Confronting New Medicare Payment Realities: What CAP Members Need to Know about the 2014 Physician Quality Reporting System (PQRS)â€�, featuring Jonathan L. Myles, MD FCAP, Chair, CAP Economic Affairs Committee (EAC) Pathology Advisor, AMA RUC and Diana Cardona, MD FCAP, Chair, EAC Measures and Performance Assessment Sub-Committee. CAP members will learn about:
- The 2013 PQRS still underway;
- What’s New for PQRS in 2014; and
- The Value-Based Modifier Program.