Pathology, Cytology Face Potential Cuts in 2017 Physician Fee Schedule

CPT Code 88305 is headed to the chopping block again. The Centers for Medicare & Medicaid Services (CMS) has suggested cutting the technical component of 88305—a tissue examination and a primary component within the practice of pathology—by 15 percent for calendar year 2017 as part of its proposed changes to the Medicare Physician Fee Schedule.

The pathology world was shaken to the core three years ago when the technical component of 88305 was cut by 57 percent. The decision by CMS to dramatically ratchet down reimbursement then led to the devaluation of many pathology practices. There have been other cuts since then, but they have remained below double digits percentagewise.

The proposed cut to 88305 would bring the technical portion of 88305 below $30, to $29.34. The proposed rate for professional interpretation remains essentially unchanged at $39.71.

The Physician Fee Schedule is a delicate ballet wherein CMS tries to reconcile the intellectual challenge of performing each task with how much time it takes to complete in order to compute how much Medicare will reimburse for each procedure. The agency tries to assign specific values to the work through what is known as relative value scale. The higher the value, the more laborious or complicated the task.

For this latest round of proposed cuts, the CMS said prices have dropped for some disposables to perform pathology services, particularly eosin stain supplies. That has also led to other smaller cuts to 14 other pathology-related CPT codes and G-code G0416, which pertains to prostate needle biopsies.

Another significant change is proposed reductions in payments around CPT code 88184, which pertains to flow cytometry/tc1 markers. The proposed cuts range from 3 cents to more than $5, depending on the work task related to the use of the assay. Each antibody flow cytometry test would be cut by $5.10 (input code SL186). But the dye sublimation printing attached to the task (input code ED031) would see just the smallest cut.

According to CMS, that is due to refinements connected to the amount of time such equipment is being used. However, the reductions total about a 20 percent cut in reimbursement around a significant amount of flow cytometry work.

The College of American Pathology and American Clinical Laboratory Association have yet to submit formal comments on the proposed rule, which impacts virtually every medical practice that accepts Medicare patients. CMS is accepting input through much of the next month.

The "proposals are intended to give a significant lift to the practice of primary care and to boost the time a physician can spend with their patients listening, advising and coordinating their care—both for physical and mental health," said CMS Acting Administrator Andy Slavitt in a statement.

Some pathologists have expressed displeasure in early comments submitted to the agency.

"For the second time in four years, another reduction on primary Pathology codes is being proposed. The first reduction was dramatic, this second would be catastrophic," remarked Ana L. Viciana, M.D., a pathologist in Miami, Fla. "Pathology services simply can barely afford to be provided adequately. The continued reduction in reimbursement results in an inability to maintain the level of professional services required to reduce medical errors!"

Megan Kressin, M.D., a pathologist in Austin, Tex., also expressed concern.

"These proposed fee reductions are extreme, and will challenge the ability of the pathology laboratory to accurately and quickly diagnose a patient's tumor. Histology is a delicate and time consuming art that can result in suboptimal tissue for diagnosis if rushed. Under the proposed fee codes, labs will be forced to reduce their histology workforce and overly burden an already stressed histology workforce," Kressin remarked. "Similarly, flow cytometry is the cornerstone of diagnosis for many leukemia and lymphoma cancers. A 20 percent reduction will challenge many labs to be able to continue to offer this vital and time-sensitive testing. My hospital must perform flow cytometry within an hour of sample collection in order to determine if there are enough cells for a bone marrow transplant; this is not a test that can be outsourced and it requires significant time, expertise, and equipment. This fee reduction would be devastating for the patients who depend on an accurate and timely pathology diagnosis for their treatment."

Takeaway: The CMS is proposing more significant cuts to the practice of pathology in its 2017 Physician Fee Schedule.