In August, the CAP met with the Centers for Medicare and Medicaid Services (CMS) to advocate for an increase in the cytotechnologist labor rate. In the 2024 Medicare Physician Fee Schedule, the CMS agreed with the CAP’s request and finalized a two-year, phased-in increase of 12% starting in 2024. This increase was supported by public wage survey data and more accurately reflects cytotechnologist education, job duties, workforce shortages, and recruitment challenges. The following table summarizes the impacts to a sample of codes based on this change. The relative value units (RVUs) should continue to increase in 2025 as part of the phase-in.

Pathologists providing cytopathology and flow cytometry services stand to benefit from the CAP’s advocacy win in their practice expense methodology to determine physician fee schedule payment. Services paid through the Medicare physician fee schedule have two components: a physician work component and a technical component. The technical component represents the clinical (non-physician) labor, medical supplies, and equipment used to furnish a particular service. Clinical labor is represented as a per minute expense, with the CMS determining the rate paid for each clinical labor type as a component of the practice expense RVU and payment rate.

Last year, the CAP advocated for a separate increase to the histotechnologist clinical labor rate. This increase was finalized in the 2023 Medicare physician fee schedule and continues to be phased-in over the coming two years. As a result of these two policies, many pathology services may experience an increase in their technical component and global payments in both 2024 and 2025.

This advocacy win highlights the role of practice expense in determining pathology reimbursement. Physicians should be on the lookout for two recent practice expense surveys from Mathematica. The first survey will seek practice expense information from individual practices, while the second survey will collect patient care hour data from individual physicians. It is vital that pathologists complete this survey as this specialty-level data will be shared with the CMS to update the Medicare Economic Index and practice expense relative values on the physician fee schedule. To learn more about the PPI (Physician Practice Information) Survey click here.