The College of American Pathologists (CAP) has serious concerns with proposals by the Centers for Medicare and Medicaid Services (CMS) to package payment for certain pathology services into ambulatory payment classifications (APCs) under the Hospital Outpatient Prospective Payment System (HOPPS). Under a rule released July 14, 2014, CMS is proposing to conditionally package payment for ancillary services which have a geometric means cost of $100 or less. This would include APC 0342, Level I pathology services. APC 0345, Level 1 transfusion laboratory services, and APC 0433, Level II pathology procedures. The agency is also proposing to package certain add-on services and certain pathology professional services. In comments to the rule submitted Aug. 29, CAP says it believes that “CMS is again proposing an unwarranted and untested expansion of bundling without first taking adequate steps to define the proposals in sufficient detail to engage with stakeholders to understand the impact of the proposal on affected groups, or to anticipate possible consequences that could adversely affect quality of care and access to services.” Specifically, CAP notes that CMS is proposing to package the technical components of more than 215 physician services, including more than 30 pathology physician services, without any way of […]
The College of American Pathologists (CAP) has serious concerns with proposals by the Centers for Medicare and Medicaid Services (CMS) to package payment for certain pathology services into ambulatory payment classifications (APCs) under the Hospital Outpatient Prospective Payment System (HOPPS).
Under a rule released July 14, 2014, CMS is proposing to conditionally package payment for ancillary services which have a geometric means cost of $100 or less. This would include APC 0342, Level I pathology services. APC 0345, Level 1 transfusion laboratory services, and APC 0433, Level II pathology procedures. The agency is also proposing to package certain add-on services and certain pathology professional services.
In comments to the rule submitted Aug. 29, CAP says it believes that “CMS is again proposing an unwarranted and untested expansion of bundling without first taking adequate steps to define the proposals in sufficient detail to engage with stakeholders to understand the impact of the proposal on affected groups, or to anticipate possible consequences that could adversely affect quality of care and access to services.”
Specifically, CAP notes that CMS is proposing to package the technical components of more than 215 physician services, including more than 30 pathology physician services, without any way of determining whether these services will be appropriately reimbursed or if physicians will receive payment for their services at all in 2015.
“It is important to recognize that any of these services may often be medically necessary multiple times each day per primary service,” the college writes. “Each of these services has different medically necessary utilization patterns based on each particular patient’s specific conditions. To establish and apply a packaged reimburse rate that includes such services is likely to result in inaccurate and therefore, sometimes inadequate, compensation for services delivered.”
CAP also noted that the packaging policies create significant administrative burden for pathology practices and would necessitate that many pathology practices receiving specimens from hospitals renegotiate their hospital contractual arrangements, which could result in another very substantial impact on the reimbursement of laboratory tests.
The college also opposes plans by CMS to package all add-on codes furnished as part of a comprehensive service as well as plans to reimburse Current Procedural Terminology codes 88187, 88188, and 88189 under the HOPPS schedule. “We are unclear why these services are included in the [H]OPPS as they relate to the physician’s professional service of interpretation of flow cytometry,” writes CAP. “These codes are generally billed by physicians rather than by facilities.”
In addition, CAP questions the inclusion of the following three codes as unconditionally packaged under the proposed rule: 88380 (microdissection laser), 88381 (microdissection manual), and 88387 (tissue exam molecular study). “Other services in the molecular space that are packaged are on the clinical laboratory fee schedule while these services . . . are on the physician fee schedule.”
Takeaway: The College of American Pathologists opposes proposals by Medicare to package payment for additional pathology services under the Hospital Outpatient Prospective Payment System.
