Advocacy Update

July 25, 2023

In this Issue:

State Pathology Societies and CAP Seek to Expand Coverage of Palmetto’s Policies on Special Stains

State Pathology Societies and the CAP called on the Medicare Administrative Contractor (MAC) Palmetto to remove certain coverage limitations to its special stains Local Coverage Determination (LCD). The CAP has long opposed Palmetto’s policies on special stains and has collaborated with state pathology societies in Palmetto’s jurisdiction in an effort to make necessary changes supported by medical evidence.

In December 2021, the CAP sent a formal appeal to Palmetto with proposed revisions to the local coverage determination (LDC) that denies Medicare coverage of special histochemical stains, and immunohistochemical stains and/or special stains for breast, gastrointestinal, and prostate tests under the current LCD.

On July 17, Palmetto hosted a virtual public meeting in designated jurisdictions to discuss the proposed revisions. Pathology Contractor Advisory Committee members representing pathology state societies from Georgia, North Carolina, South Carolina, and West Virginia provided comments on the clinical necessity of IHC and special stains for breast and GI cancers. They also voiced their support for the CAP’s formal comment letter submitted to Palmetto on July 17 that urged further clarification and encouraged expanded coverage including Ki-67, special stains and IHC for prostate, and MMR/MSI testing. State pathology societies also made compelling arguments at the public meeting on the necessity for expanding coverage for prostate stains.

The CAP will continue to advocate through formal comment letters and support from state pathology society contractor advisory committee representatives.

Read CAP’s comment letter

CAP President Speaks Out Against Cytotechnologist Name Change During Open Hearing

On July 21, CAP President Emily E. Volk, MD, FCAP gave testimony to the Commission on Accreditation of Allied Health Education Programs opposing a name change to “cytologists” for cytotechnologists during an open hearing on the Standards and Guidelines for Accreditation of Educational Programs in Cytology.

The CAP opposes the interchangeability between the professional designations of “cytotechnologist” and “cytologist.” The term “cytotechnologist” has been in use since the 1950s, to describe a medical professional trained in the identification of cells and cellular abnormalities. For weeks, the CAP has been sounding the alarm encouraging members to submit written comments opposing the name change to eliminate confusion over roles and responsibilities in the laboratory workflow and remove the potential of jeopardizing individual patient health outcomes.

Dr. Volk stated: “We believe clarity in language pertaining to the variety of roles in the clinical laboratory is important as it potentially impacts government regulations, health care policy, as well as patients. If adopted, we are concerned this would increase the likelihood of role confusion and mislead healthcare policymakers, regulators, and patients. As pathologists, we find that this proposed name change runs counter to our efforts to create clarity in terminology in pathology and laboratory medicine.”

ONC Accepts CAP’s Suggestions for Next Version of Interoperability Data Standard

On July 20, 2023, the Office of the National Coordinator for Health Information Technology (ONC) finalized version 4 of the United States Core Data for Interoperability (USCDI). The USCDI standard, which the ONC adopted in the 21st Century Cures Act defines how health care data must be formatted to be exchanged electronically nationwide. The USCDI standard enables the same health care data to be understood across different institutions. Data sharing through widely accepted standards is critical to ensure that health information is available and comprehensible across care settings for use in patient care, public health, and emergency (eg, pandemic) preparedness and response.

On April 17, 2023, the CAP sent a comment letter on this issue to the ONC, which is tasked with promoting the use of the most advanced health information technology and the electronic exchange of health information. In its advocacy to the ONC, the CAP issued suggestions on how it could improve the fourth version of the USCDI standard. The CAP’s positioning on the USCDI is that the ONC should align the USCDI with the test reporting requirements in CLIA, and that the ONC should seek to achieve its goal with USCDI without overburdening pathologists and laboratories.

Read more about version 4 of the United States Core Data for Interoperability.

In Case You missed It - CAP Urges Pathologists to Respond to AMA-Mathematica Physician Practice Expense Survey to Ensure Accurate Medicare Pay Rates

The CAP is one of more than 170 health care organizations supporting a new national study by the American Medical Association (AMA) and Mathematica that will collect representative data on physician practice expenses. The aim of the AMA Physician Practice Information Survey is to better understand the costs faced by today’s physician practices to support physician payment advocacy.

Pathologists and their practices must watch for invitations to complete the survey. Invitations and reminders about the costs survey will come from with the subject line: “American Medical Association requests your input on physician practice expense and patient care hours.” Invitations and reminders about physician hours worked will come from with the subject line: “Please help to update accurate physician payments.” Your input will ensure future pathology payment rates are accurate.

The study will serve as an opportunity to communicate accurate financial information to policymakers, including members of Congress and the Centers for Medicare & Medicaid Services (CMS). The survey will be administered from July 2023 – April 2024.

Physicians will be randomly selected to participate. If contacted, you will receive a $100 stipend for participating in the survey and your individual practice data will be kept private. Participation is voluntary but critical to the success of efforts to support accurate resource-based physician payment.

Again, the CAP strongly urges all physicians who are selected for the surveys to respond as soon as possible. For more information read the Physician Practice Information Survey Methodology Report.

New Podcast: 2023 AMA Recap Meeting with Dr. Sanfrancesco

Physicians across the nation gathered to discuss issues regarding their patients and US health care policies at this year’s AMA meeting in Chicago. Listen to our CAPcast with Joe Sanfrancesco, MD, FCAP, recapping some of the most important moments.

CAP’s Advocacy Newsletter Wins Award for Publication Excellence

The CAP recently received a communications award for publication excellence at the 35th Annual APEX Awards for Publication Excellence in the 1-2 person-produced newsletter category.

The awards were based on excellence in graphic design, editorial content, and the success of the entry in achieving overall communications effectiveness and excellence. Over 1,000 entries were evaluated, and 453 APEX Awards of Excellence were recognized in 100 individual subcategories. See the list of winners here.

Register: Proposed 2024 Medicare Physician Fee Schedule Webinar

Do you know how much your Medicare pay will increase or decrease in 2024? Register in advance for our proposed 2024 Medicare Physician Fee Schedule webinar on July 26 at 1 PM ET/ Noon CT. During this session, you will learn the latest Medicare payment policies concerning individual pathology services and the Quality Payment Program next year.

Our expert presenters will also answer your questions. They are Jonathan Myles, MD, FCAP, chair, Council on Government and Professional Affairs; Diana Cardona, MD, FCAP, chair, Quality and Clinical Data Registry Affairs Committee; and Ronald W. McLawhon MD, PhD, FCAP, chair, Economic Affairs Committee. Secure your attendance for this complementary program today.

Take Our News Quiz for July

Are you up to speed on CAP advocacy news? Take our new monthly news quiz and see how many you can get right and share your results on social media.

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