The CAP has sought additional Medicare funding to train pathologists and increase pay for pathology services delivered in the hospital inpatient setting in 2025. In the proposed 2025 Hospital Inpatient Prospective Payment System regulation, the CAP has asked the Centers for Medicare & Medicaid Services (CMS) to increase residency slots for pathology, increase costs associated for gene therapies for sickle cell disease (SCD) and provide payment adjustments for certain clinical trial use for immunotherapy cases.

Proposed Payments for Indirect and Direct Graduate Medical Education Costs

In the June 10 letter to the CMS, the CAP outlined the critical need to increase pathology slots in residency programs. The CAP stressed that physician shortages are occurring in specialty areas such as pathology, especially in rural areas. The pathology workforce is not keeping up with patient growth and population changes. The CAP urged the CMS to create opportunities and incentives for the pathologist workforce to expand as needed to meet population growth and ageing.

Proposed Increase of Costs of New Technology for Gene Therapies for Sickle Cell Disease (SCD)

The CAP supported the proposed increase of estimated costs of the new technology for gene therapies indicated and used in the treatment of sickle cell disease and urges the agency to finalize this proposal. The CAP does not support making this proposed increase contingent on applicants meeting additional criteria or engaging in behaviors that promote access to these therapies at a lower cost. The agency has already acknowledged that these gene therapies for SCD have the potential to improve the health of the impacted beneficiary, leading to long-term savings in the Medicare program; adding additional criteria would likely reduce access to these therapies.

Proposed Revision to Labor Market Area Delineations and Continuation of Low Wage Index Hospital Policy

The CAP recognizes that Medicare payments to hospitals (and various other provider types) are adjusted by a wage index intended to account for geographic differences across labor markets. The CMS updates the wage index annually based on hospital cost report data and other inputs and policies. This year, the CMS proposed two significant changes that would affect the wage index - revised labor market delineation and low wage index hospital policy. The CAP supported these proposals to update the wage index and urged the CMS to finalize these changes.

Payment Adjustment for Certain Clinical Trial and Expanded Access Use for Immunotherapy Cases

The CMS also proposed to continue to exclude clinical trial cases, which do not include the cost of the CAR T-cell product itself, from the calculation of the relative weight from MS-DRG 018. The CAP in its comments agreed with the CMS proposal to continue to exclude CAR T-cell clinical trial cases from the calculation of the relative weight of the MS-DRG 018 and urged the CMS to finalize this proposal. Additionally, the CAP urged the CMS to take issues such as the use of CAR T-cell in clinical trials into account as the agency updates the MS-DRG 018.

The CAP also provided feedback on Public Health eReporting request for information, opposing any new requirements that would increase burden for clinicians or impose undue hardship on pathologists.