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- The CAP Urges CMS to Maintain Current APC level for CPT Code in Final Hospital Outpatient Regulation
The CAP asked the Centers for Medicare & Medicaid Services (CMS) to reevaluate the ambulatory payment classification (APC) for cytopathology CPT code 88121 in the proposed 2023 Hospital Outpatient Prospective Payment System and Ambulatory Surgery Center Payment System regulations. The CAP advocates fair payment for all services pathologists provide—actively representing pathologists’ interests in nearly every payment-related policy discussion.
In the September 13 letter to the CMS, the CAP outlined how the proposed recalibration of APC Relative Payment Weights for CPT Code 88121 would be a detrimental rate-setting issue for pathologists. The data will not reflect the actual cost of these specific and complex diagnostic procedures by recalibrating and grouping several services or procedures into appropriate clinically and economically homogeneous APCs. “The costs associated with performing this service is nearly three times the cost of an APC 5672 “Level 2 Pathology” service, based on physician fee schedule technical component cost differences. This proposed reassignment creates a resource cost rank order anomaly with other physician services and the technical costs will not be fully recovered from each unit of service,” the CAP stated. Therefore, the CAP wants to CMS to maintain the assignment of APC 5673 for CPT code 88121.