There are defining moments when the strength of a professional organization is measured by the unity of its members. This is one of those moments, and it calls on us to rise together with a clear, collective voice.
For decades, the College of American Pathologists (CAP) has championed patients, advanced our specialty, and safeguarded the value of the pathology services you provide. Today, we face a new challenge that goes to the core of our profession.
Last month, the Centers for Medicare & Medicaid Services (CMS) released its proposed 2027 Medicare Physician Fee Schedule. Within the proposal is a development with potentially far-reaching consequences for pathologists and our patients: CMS has identified surgical pathology services for possible revaluation based on concerns that they may be overvalued.
The surgical pathology code family, including commonly used service codes such as 88305 and 88307, represents the foundation of diagnostic medicine. These services guide treatment decisions for patients facing cancer and other serious diseases. Yet under the proposed process, these services could face substantial payment reductions in future years, potentially beginning as early as 2027. On August 12, we’ll discuss the implications in greater detail during our webinar.
CMS relied on a Maryland Health Care Commission analysis that used claims data to estimate pathologists’ work time. That methodology led to implausible conclusions, including the suggestion that pathologists performed more than 24 hours of work in a single day, and those findings were used to support the claim that surgical pathology services may be overvalued.
The CAP strongly disagrees.
The analysis fails to account for the realities of pathology practice, including longstanding Medicare billing rules, reassignment requirements, date-of-service reporting conventions, and claims data not capturing all intraservice time spent on our services. As a result, flawed assumptions have been used to justify a revaluation effort that threatens payment stability and, ultimately, patient access to high-quality diagnostic medical services.
Let me be clear: the CAP is fully engaged in this effort and will fight aggressively on behalf of our members and our patients.
CAP staff and physician leaders are thoroughly analyzing CMS’s proposal, preparing detailed comments, engaging policymakers, and building the evidence needed to defend the value of surgical pathology services. Our goal is to ensure Medicare payment reflects the physician expertise, judgment, and responsibility these essential services require.
This challenge underscores why the CAP exists.
When pathology services are threatened, the CAP acts. When policymakers rely on flawed assumptions, the CAP brings evidence and expertise forward. And when the future of our specialty is at risk, the CAP advocates tirelessly for pathologists and the patients who depend on us.
We will keep you informed as this effort progresses. In the weeks ahead, your engagement and support will be critical as we work together to protect the future of our profession.
Together, we will make the case for pathology.
