The CAP had advocated to increase clinical labor pricing in 2023 and asked the Centers for Medicare & Medicaid Services (CMS) to finalize it in the final regulation. Additionally, the CAP urged the CMS to finalize the prices of certain supplies and equipment, clarify the MIPS Value Pathway requirements, reinstate MIPS bonus points for high-performing physicians and clarify the pathology quality measures for the 2023 Quality Payment Program. The CAP continues to fight for fair reimbursement and reduce reporting burdens for pathologists.

Medicare Physician Fee Schedule

In the September 2 letter, the CAP urged the CMS to finalize clinical labor pricing rates that it spent the last year advocating to correct. The CAP asked the CMS to finalize the increased clinical labor rates, which will be phased in over the next three years. The CAP specifically asked the CMS to finalize the histotechnologist’s labor rate increase which would be greater than 16% of what the CMS previously finalized. Additionally, the CAP requested that the CMS finalize a pricing update of six supplies and two equipment items in the proposed 2023 Medicare Physician Fee Schedule to enhance the accuracy of the costs associated with several pathology services.

Quality Payment Program (QPP)

The CAP appreciated that CMS is limiting changes to the MIPS program but encouraged CMS not to finalize changes to scoring on measures that make it harder for pathologists to reach the scoring threshold. To that end, the CAP strongly urged the CMS to reinstate the MIPS bonus points for high-priority measures and asked that the CMS maintain the 3-point floor for quality measures, especially considering the removal of bonus points for high-priority and outcome measures. Additionally, the CAP urged the agency to remove the proposed Screening for Social Drivers of Health measure from the proposed 2023 pathology measure set as it does not align with non-patient-facing pathology practice.

The CAP also encouraged the CMS to ensure that independent pathology practices can be successful as the QPP evolves. However, until such time as the new MIPS Value Pathways (MVPs) allow single-specialty, independent pathology practices to be successful, the CMS should continue traditional MIPS.