The CAP successfully advocated for the inclusion of new and improved codes and values for pathology consultation services in the proposed 2022 Medicare Physician Fee Schedule.

The CAP had worked with the American Medical Association’s (AMA) CPT Editorial Panel to improve the pathology consultation codes and develop new payment rates through its role in the AMA/Specialty Society Relative Value Scale Update Committee (RUC). The Centers for Medicare & Medicaid Services (CMS) accepted the new code family proposed by the CAP in the 2022 Medicare proposed fee schedule.

Advocacy Win: New Pathology Consultations Codes Added

Each year, the CAP advocates for the valuation of all pathology services. The current pathology consultation services (codes 80500 and 80502) were previously identified as potentially misvalued. Consequently, the CAP worked with the AMA CPT Editorial Panel to delete 80500 and 80502, modernize and create the new Pathology Clinical Consultation family of four codes. Then the CAP worked with the RUC to develop physician work and practice expense values for the new Pathology Clinical Consultation codes. The CAP leads all reviews of pathology services that go before the RUC. Once the fee schedule is finalized, pathologists can begin using the new codes to bill these services in 2022.

As part of the pathology consultation codes review, the CAP analyzed Medicare claims utilization data and observed confusion regarding proper reporting of these services and miscoding. The RUC agreed with the CAP’s request to refer the 80500-code family to the CPT Editorial Panel to develop proper instructions and a CAP proposal for coding structure refinement.

The CAP applauds the CMS proposed decision to implement the new Pathology Clinical Consultation services in 2022. The new pathology clinical consultation services (80XX0, 80XX1, 80XX2, 80XX3) describe physician pathology clinical consultation services provided at the request of another physician or qualified health care professional at the same or another facility or institution.

According to CPT, the pathology clinical consultation services (80XX0, 80XX1, 80XX2, 80XX3) may be reported when the following criteria have been met:

• The pathologist renders a pathology clinical consultation at the request of a physician or qualified healthcare professional at the same or another institution.
• The pathology clinical consultation request concerning to pathology and laboratory findings or other relevant clinical or diagnostic information requiring additional medical interpretative judgment.

Proposed Fee Schedule Impact on Pathology Payment

The CMS also estimates the overall impact to pathology payment in 2022 should the agency finalize this rule as proposed. According to the CMS reimbursement for pathology services would decrease by 1% due to changes practice expense pricing. In addition, the proposed 2022 conversion factor used for the fee schedule’s payment formula is $33.5848, representing a 3.75% decrease from the 2021 conversation factor. This 3.75% decrease to the conversion factor stems from Medicare policy to offset increases to other physician services such as any increases to evaluation and management services.

Review all the proposed changes to pathology services in our proposed 2022 Medicare Physician Fee Schedule Impact Table.

What Will Be the Impact of the Proposed Fee Schedule on Your Practice?

CAP members can learn more about the proposed fee schedule changes by attending a complimentary webinar on August 5 at 1 PM ET where experts will review the proposed 2022 Medicare regulations and their impact on payment for pathology services.

Register today