The CAP successfully advocated to include new CPT codes for pathology clinical consultation services in the proposed 2022 Medicare Physician Fee Schedule but urged the Centers for Medicare & Medicaid Services (CMS) to clarify the codes before implementation. Additionally, the CAP asked the CMS to relieve some quality reporting burdens for pathologists as the CAP advocates to ensure adequate reimbursement coverage issues facing pathologists.

Pathology Consult Codes Implementation

In a September 13 letter to the CMS, the CAP outlined how the CMS should view and implement the pathology clinical consultation codes next year. The CAP worked with the American Medical Association’s (AMA) CPT Editorial Panel to craft new pathology clinical consultation codes and develop payment rates through its role in the AMA/Specialty Society Relative Value Scale Update Committee (RUC). As a result, the CMS accepted the new code family proposed by the CAP in the 2022 Medicare proposed fee schedule.

The CMS adopted the CAP developed relative value units (RVUs) with some areas of disagreement. In the letter, the CAP encouraged the CMS to fully adopt the CAP’s recommended RVUs and disagreed “with the CMS’ assessment that the increase or decrease in time is commensurate with the increase or decrease in work RVU. The code set 80XX0 – 80XX3 represents unique and distinct services from those identified by 80500 and 80502. 80500 and 80502 are almost 25 years old and represented different services and should not be used for comparison,” the CAP stated.

The AMA RUC adopted the CAP’s developed values from pathologist’s survey data for these services. The surveys measured their clinical judgment, mental effort, technical skill, and psychological stress relative to other physician fee schedule CPT codes, to develop the amount of physician work and time for each code. The CAP urged the CMS to embrace the RUC processes in its final 2022 fee schedule valuations.

Proposed 2021 Merit-based Incentive Payment Program (MIPs)

Also, in the September 13 letter, the CAP advocated to increase flexibility for pathologists in a way that recognizes and accounts for the value pathologists play in patient care as non patient-facing clinicians in an inherently patient-facing program. These considerations will be especially important as the CMS moves forward with implementing the Merit-based Incentive Program (MIPS) Value Pathways (MVPs) in the Quality Payment Program (QPP). Additionally, the CAP responded to the digital quality measures and health equity requests for information (RFI). It urged the CMS to consider the CAP’s concerns before implementing policies included in these RFIs.