In the proposed Hospital Inpatient Prospective Payment System regulation, the CAP asked the Centers for Medicare & Medicaid Services (CMS) to increase residence slots for pathology, monitor, and evaluate CAR T-cell therapies, and increase stratification of quality measures in hospital reporting programs. The CAP advocates fair payment for the value pathologists provides and reduced regulatory burdens on pathologists.

Proposed Payments for Indirect and Direct Graduate Medical Education Costs

In the June 17 letter to the CMS, the CAP outlined the critical need to increase pathology slots in residency programs. Much like our population, the physician workforce is aging, with nearly 45 percent of active physicians in the United States being 55 and older. In the letter, the CAP stated that physician shortages in specialty care are “significant and are often overlooked by policy makers at this time when primary care is at center stage.”

Payment Adjustment for CAR T-cell Clinical Trial and Expand Access Use Immunotherapy

Additionally, the CAP supported the CMS’s efforts to assess the appropriateness of the therapies assigned to MS–DRG 018 and its continued work with stakeholders to evaluate the resource costs to improve the predictability and stability of hospital payments for complex, novel cell therapies, such as CAR T-cell therapy. Pathologists play a critical role as integral members of the cancer patient management team, including patient education, care management, and providing CAR-T cell therapy clinical services. With its increased use, CAR-T-cell therapy is an expensive, evolving service with unique challenges. The CAP asked the CMS to consider these issues as the agency updates the MS-DRG 018 Chimeric Antigen Receptor (CAR) T-Cell and Other Immunotherapies.

Quality Data Reporting Requirements for Providers Changes

The CAP supported the CMS’ proposed stratification of quality measures in hospital reporting programs so clinicians can identify areas to advance health equity and made recommendations on implementation tactics. For example, the CAP suggested that the CMS “consider measures for stratification individually or by specialty rather than a one-size-fits-all approach.” Additionally, the CAP suggested that CMS:

1. Ensure that all efforts generate actionable data that reflect meaningful differences between clinicians
2. Communicate the implications of stratification prior to making any payment-related decisions
3. Provide feedback on stratification, including the ability to request that stratification is changed, removed, or added based on available data, and avoid sub-regulatory actions that could compromise the process.

Additionally, the CAP asked the CMS to consider logistics when transitioning Digital Quality Measures, data standardization, and FHIR-based reporting for electronic clinical quality measures. The CAP opposes any new requirements that would increase burden for clinicians or impose undue hardship on pathologists.