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.