In the proposed 2022 Medicare Physician Fee Schedule, pathologists were set to face an additional Medicare cut of 1% due to updates to practice expense clinical labor rates used to calculate payment rates for services. Thanks to opposition from CAP advocacy, the Centers for Medicare & Medicaid Services (CMS) agreed to delay that update, which averted this specific 1% cut to pathology services next year.

On November 2, the CMS published the final 2022 fee schedule with information about the delay to the practice expense changes and other details on how much pathologists will be paid for their services next year. The CAP sent its members an initial analysis of these changes within hours of the fee schedule’s publication. The analysis included the CAP’s impact table showing the changes in Medicare payment rates for pathology services on the fee schedule from 2021 to 2022.

While the CAP has so far been successful in mitigating one Medicare cut to pathologists, overall payment rates are expected to decrease by 3.7% next year. The CAP has lobbied Congress throughout 2021 to further mitigate cuts to pathologists and other physicians.

New Pathology Clinical Consultation Codes

Pathologists will have new CPT codes for pathology clinical consultation services in 2022 after the Medicare program included codes developed by the CAP in its final fee schedule. The CAP had worked with the American Medical Association’s (AMA) CPT Editorial Panel to establish pathology clinical consultation codes and develop new payment rates through the CAP’s role in the AMA/Specialty Society Relative Value Scale Update Committee (RUC). The CMS also finalized the values for the new pathology consolation codes. The agency accepted most of the CAP developed relative values for the pathology clinical consultation services.

The four new pathology clinical consultation services describe physician pathology clinical consultation services provided at the request of another physician or qualified health care professional at the same or another facility or institution. The distinction among the new code family involves a degree of complexity and/or time of service, broken down by 20-minute increments each for codes 80503, 80504, and 80505, along with an add-on code 80506 reflecting additional 15-30 minutes above that spent on CPT 80505.

Also on November 2, the CMS published its final regulation for the 2022 Quality Payment Program (QPP). According to the final regulation, nearly all pathologists will be required to participate in Medicare’s QPP either through Advanced Alternative Payment Models (APMs) or the Merit-based Incentive Payment System (MIPS).