Factors negatively impacting pathology in the proposed 2026 fee schedule include a proposed efficiency adjustment to the physician work RVUs.
- According to CMS, it “may help to improve the overall accuracy of valuation of services under the PFS.”
CPT Codes for CAR-T Therapy Services
In 2023, the CAP and a multispecialty group developed four new category I CPT codes to describe the procedures required for creating and administering CAR-T therapy, which is a treatment for certain types of cancer.
Despite agreeing with recommended work RVUs, CMS decided to bundle payment for CAR-T cell harvesting and preparation into one code.
- This meant no separate payments for each service under the fee schedule or hospital outpatient prospective payment system.
- The policy took effect on January 1, 2025.
The CAP met with CMS to oppose the finalized policy, arguing it doesn’t recognize pathologists’ work.
- CMS should pay separately for each CPT code service.
- The CAP followed up with a letter to CMS seeking clarity on the policy.
CMS still proposes not providing separate payment, but the agency is now soliciting comments on this policy.
What’s next: The CAP will continue to advocate on this important issue.
By the numbers: According to CAP calculations, the proposed fee schedule will result in a 0.56% increase in pathology payments from 2025.
- The non-APM qualifying conversion factor for 2026 is $33.4209, up 3.3% from 2025, largely due to an adjustment from the One Big Beautiful Bill Act.
- The CAP is actively lobbying Congress to ensure that this increased funding is made permanent.