The CAP submitted comments on the proposed 2027 Medicare Physician Fee Schedule, urging CMS to protect pathology services and avoid payment policies that could negatively affect patient care.
Key concerns include:
- Proposed changes to surgical pathology services: We opposed revisions to physician work values for the CPT code 88305 family based on an analysis from the Maryland Health Care Commission, arguing the analysis does not adequately reflect the complexity and diversity of pathology services used to diagnose cancer and other serious diseases.
- Payment for software-based laboratory services: We opposed moving certain Software as a Medical Service (SaMS) laboratory analyses from the Clinical Laboratory Fee Schedule to the Physician Fee Schedule, warning the change could place additional pressure on physician payment and create uncertainty around reimbursement for these technologies.
- Quality Payment Program proposals: We urged CMS to address operational issues with MIPS Value Pathways before fully transitioning away from traditional MIPS and raised concerns about reporting requirements, scoring changes, and administrative burden for pathology practices.
The bottom line: Our comments urged CMS to protect access to pathology services and rely on clinically informed processes when considering changes that could affect patient care.