The proposed 2025 Medicare Physician Fee Schedule released on July 10 highlights the continuous advocacy efforts by the CAP to protect the value of pathology services. Due to the CAP’s efforts, the Centers for Medicare & Medicaid Services (CMS) has proposed to increase the relative values of three apheresis services, provide coverage for four new CAR T-cell services, and increase the clinical labor rates for key laboratory clinical labor types. The proposed 2025 Medicare Physician Fee Schedule does, however, include cuts to physicians, including pathologists, and other providers such as independent laboratories. These cuts largely stem from the expiration of two congressional Medicare pay relief packages that were intended to offset the previously finalized cuts in the 2023 and 2024 Medicare Physician Fee Schedules. The CAP strongly opposes these cuts and is actively lobbying Congress to mitigate the decreases before they take effect.

The CAP will provide comments to the CMS within the next 60 days on the proposals that impact the specialty. Briefly, here are the key issues influencing payment for pathology services in the 2025 proposed rule:

• The continued budget neutrality adjustments and the expiration of congressional relief continue to negatively affect pathologists and other specialties throughout the physician fee schedule. Download the impact table showing the proposed changes to pathology services in 2025.
• The CMS increases Medicare Quality Payment Program (QPP) requirements for 2025, making it more difficult for eligible clinicians to thwart off payment penalties.
• Learn more: Register for the CAP’s July 30 webinar providing a comprehensive overview of the proposed fee schedule changes to pathology services and the QPP.

In its proposed 2025 Quality Payment Program regulations the CMS will:

• Leave the performance threshold to 75 points for 2025. The CAP supports CMS’ decision not to raise it.
• Maintain the data completeness threshold at 75 points for 2025, a previously finalized policy
• Not add or remove any measures from the Pathology Specialty Measure Set
• Reduce the available options for Improvement Activities, including several IAs that are commonly performed by pathologists

The CAP continues to advocate for pathologists’ success in the MIPS program. We encourage practices (and their billing companies) to review the scoring changes and contact CAP at mips@cap.org to understand the availability of higher-scoring measures and how to best report them.