Blog

The American Society for Clinical Pathology (ASCP) has submitted a letter to the Centers for Medicare & Medicaid Services (CMS) requesting that CMS revise its CY 2017 Physician Fee Schedule Proposed Rule.

Here are some of the key points to know about ASCP's request:

1. The proposed rule outlined CMS's desire to significantly reduce payment rates for a number of pathology services, such as immunohistochemistry, morphometric analysis, flow cytometry, microslide consultation, prostate biopsies and cytopathology interpretations.

2. CMS projects that the policy changes it proposed would decrease pathology billing reimbursement by 2% and independent clinical laboratory billing reimbursement by 5%.

3. ASCP raised concerns about plans to cut payment rates for immunohistochemistry and morphometric analysis add-on codes by reducing the physician work component by 20%.

4. ASCP disagreed with the CMS proposal to reduce reimbursement for the prostate biopsy G-code G0416 as the proposal did not properly value the amount of work involved.

5. ASCP asked CMS to restore the Refinement Panel, which CMS has not used in recent years. This panel serves as a means to appeal certain payment rates adopted by CMS.

6. ASCP asked CMS to modernize the Stark Law's in-office ancillary services exception to prevent the self-referral of anatomic pathology services by clinicians.

Learn more about ASCP.

The Centers for Medicare & Medicaid Services has announced it will allow providers to "pick your pace" of participation in the Quality Payment Program included in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Understanding Your Options

The options identified by CMS are as follows:

1. Test the Quality Payment Program. With this option, as long as you submit some data to the Quality Payment Program, including data from after January 1, 2017, you will avoid a negative payment adjustment. This first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.

2. Participate for part of the calendar year. You may choose to submit Quality Payment Program information for a reduced number of days. This means your first performance period could begin later than January 1, 2017 and your practice could still qualify for a small positive payment adjustment. For example, if you submit information for part of the calendar year for quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a small positive payment adjustment. You could select from the list of quality measures and improvement activities available under the Quality Payment Program.

3. Participate for the full calendar year. For practices that are ready to go on January 1, 2017, you may choose to submit Quality Payment Program information for a full calendar year. This means your first performance period would begin on January 1, 2017. For example, if you submit information for the entire year on quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a modest positive payment adjustment. We’ve seen physician practices of all sizes successfully submit a full year’s quality data, and expect many will be ready to do so.

4. Participate in an advanced alternative payment model in 2017. Instead of reporting quality data and other information, the law allows you to participate in the Quality Payment Program by joining an advanced alternative payment model, such as Medicare Shared Savings Track 2 or 3 in 2017. If you receive enough of your Medicare billing payments or see enough of your Medicare patients through the advanced alternative payment model in 2017, then you would qualify for a 5 percent incentive payment in 2019.

Analysis

As long as providers choose one of the participation options, they would not receive a negative payment adjustment in 2019.

The decision by CMS to offer these options came after thousands of physicians and other clinicians shared their feedback on an April proposal for implementation of the Program, with many requesting flexibility.

X