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- Fighting Medicare cuts: Protecting pathology services
In the 2026 Medicare Physician Fee Schedule, Centers for Medicare & Medicaid Services (CMS) officials have proposed new policies that would arbitrarily drive down pay for specialty services—including pathology.
Our response: The CAP strongly objects to CMS' arbitrary cuts and is seeking to reverse reductions to pathology services in the fee schedule released July 14.
Medicare proposals for 2026 affect pathologists differently, depending on a variety of factors including case mix and practice type.
Efficiency adjustments
CMS is creating "efficiency adjustments" because it believes productivity gains are not captured in physician work relative values (RVUs) used to calculate fees.
- They propose a 2.5% decrease in work RVUs for non-time-based specialty services.
- Officials think these services should be more efficient with experience and technology—and they’re planning to adjust services every three years.
For pathologists: Adjustments apply to all 129 common pathology services, including key CPT codes 88305, 88312, and 88341.
- The work RVUs assigned to 88305, for example, decrease from 0.75 to 0.73. Global and professional component (26-modifiers) payments will be affected by this policy.
Facility setting
CMS also wants to significantly reduce pay for indirect practice costs for services priced in the facility setting.
- This proposal affects the valuation of bone marrow, blood, consultations, and apheresis services in facility settings. Surgical pathology services are not affected.
- CAP's stance: The CMS' assumptions for these cuts are flawed. We’re stressing that the proposed reductions will hinder physicians' ability to deliver essential care.
The bottom line: Pay for pathology services would be higher in 2026 if not for these policies.
- The “One Big Beautiful Bill Act” increased overall physician spending by 2.5% in 2026, but pathology will see a net gain of only 0.56%.
What's next: The CAP will submit comments, meet with CMS officials, and continue opposing the adverse policies.
- The comment period for the fee schedule closes September 12.