Pathologists and independent laboratories will experience a handful of significant payment reductions for key services if CMS adopts changes released Tuesday in the 2022 Medicare Physician Fee Schedule (MPFS) Proposed Rule.
Currently, the rule proposes a 1% overall reduction for pathology reimbursements, alongside a 3% drop for independent laboratories and 6% cut for diagnostic testing facilities. The proposed 2022 conversion factor is $33.58, a decrease of $1.31 from the 2021 conversion factor of $34.89. The overall reduction is attributable to budget neutrality requirements triggered by RVU adjustments and the expiration of the 3.75% payment increase passed by Congress late last year to offset payment cuts in 2021.
Introduction of new clinical consult codes
However, much of that seemingly small cut for pathology is attributable to the decision to revamp the existing pathology consultation codes, 80500 and 80502. Taking their place will be four new codes (80XX0-80XX3), which describe physician pathology clinical consultation services provided at the request of another physician or qualified health care professional at the same or another facility or institution.
According to CPT, the codes may be used when:
- The pathologist renders a pathology clinical consultation at the request of a physician or qualified healthcare professional at the same or another institution.
- The pathology clinical consultation request concerning to pathology and laboratory findings or other relevant clinical or diagnostic information requiring additional medical interpretative judgment.
However, many other bread and butter services, including 88305, will again see significant reductions:
| CPT Code | Service | Current 2021 | Proposed 2022 | % Change 20-21 |
| 80XX0 | Path clinical consult sf 5-20 | NEW | $25.86 | N/A |
| 80XX1 | Path clinical consult mod 21-40 | NEW | $51.38 | N/A |
| 80XX2 | Path clinical consult high 41-60 | NEW | $91.69 | N/A |
| 80XX3 | Path clinical consult prolonged svc | NEW | $40.64 | N/A |
| 88112 – Global | Cytopath cell enhance tech | $67.69 | $66.83 | -1.3% |
| 88112 – TC | Cytopath cell enhance tech | $39.78 | $39.97 | 0.5% |
| 88112 – 26 | Cytopath cell enhance tech | $27.91 | $26.87 | -3.7% |
| 88120 – Global | Cytp urne 3-5 probes ea spec | $632.96 | $543.40 | -14.1% |
| 88120 – TC | Cytp urne 3-5 probes ea spec | $574.69 | $486.98 | -15.3% |
| 88120 – 26 | Cytp urne 3-5 probes ea spec | $58.27 | $56.42 | -3.2% |
| 88121 – Global | Cytp urine 3-5 probes cmptr | $456.75 | $378.84 | -17.1% |
| 88121 – TC | Cytp urine 3-5 probes cmptr | $408.25 | $332.49 | -18.6% |
| 88121 – 26 | Cytp urine 3-5 probes cmptr | $48.50 | $46.35 | -4.4% |
| 88184 | Flowcytometry/ 1st marker | $69.79 | $68.18 | -2.3% |
| 88185 | Flowcytometry/ additional marker | $23.03 | $19.48 | -15.4% |
| 88187 | Flowcytometry/read 2-8 | $36.64 | $34.93 | -4.7% |
| 88188 | Flowcytometry/read 9-15 | $62.81 | $60.79 | -3.2% |
| 88189 | Flowcytometry/ read 16+ | $85.14 | $81.61 | -4.1% |
| 88305 – Global | Tissue exam by pathologist | $71.53 | $69.86 | -2.3% |
| 88305 – TC | Tissue exam by pathologist | $33.85 | $33.92 | 0.2% |
| 88305 – 26 | Tissue exam by pathologist | $37.68 | $35.94 | -4.6% |
| 88307 – Global | Level V, tissue exam by pathologist | $290.31 | $280.10 | -3.5% |
| 88307 – TC | Level V, tissue exam by pathologist | $206.92 | $201.17 | -2.8% |
| 88307 – 26 | Level V, tissue exam by pathologist | $83.39 | $78.92 | -5.4% |
| 88309 – Global | Tissue exam by pathologist | $441.75 | $421.15 | -4.7% |
| 88309 – TC | Tissue exam by pathologist | $294.85 | $281.10 | -4.7% |
| 88309 – 26 | Tissue exam by pathologist | $146.90 | $140.05 | -4.7% |
| 88312 – Global | Special stains group 1 | $113.05 | $107.14 | -5.2% |
| 88312 – TC | Special stains group 1 | $86.19 | $81.61 | -5.3% |
| 88312 – 26 | Special stains group 1 | $26.87 | $25.52 | -5.0% |
| 88313 – Global | Special stains group 2 | $81.65 | $78.92 | -3.3% |
| 88313 – TC | Special stains group 2 | $69.44 | $67.17 | -3.3% |
| 88313 – 26 | Special stains group 2 | $12.21 | $11.75 | -3.8% |
| 88341 – Global | Immunohistochemistry (add stain) | $93.86 | $80.60 | -14.1% |
| 88341 – TC | Immunohistochemistry (add stain) | $65.25 | $53.40 | -18.2% |
| 88341 – 26 | Immunohistochemistry (add stain) | $28.61 | $27.20 | -4.9% |
| 88342 – Global | Immunohisto antibody 1st stain | $106.08 | $95.38 | -10.1% |
| 88342 – TC | Immunohisto antibody 1st stain | $70.83 | $61.80 | -12.7% |
| 88342 – 26 | Immunohisto antibody 1st stain | $35.24 | $33.58 | -4.7% |
| 88367 – Global | Insitu hybridization auto | $115.85 | $106.13 | -8.4% |
| 88367 – TC | Insitu hybridization auto | $82.00 | $73.55 | -10.3% |
| 88367 – 26 | Insitu hybridization auto | $33.85 | $32.58 | -3.8% |
| 88368 – Global | Insitu hybridization manual | $137.13 | $131.99 | -3.7% |
| 88368 – TC | Insitu hybridization manual | $95.61 | $92.02 | -3.8% |
| 88368 – 26 | Insitu hybridization manual | $41.52 | $39.97 | -3.7% |
| G0416 – Global | Prostate biopsy | $354.16 | $351.97 | -0.6% |
| G0416 – TC | Prostate biopsy | $175.51 | $180.35 | 2.8% |
| G0416 – 26 | Prostate biopsy | $178.65 | $171.62 | -3.9% |
| G0452 – 26 | Molecular path interp | $46.41 | $44.33 | -4.5% |
| P3001 | Screening pap smear by phys | $21.98 | $24.52 | 11.6% |
Comment sought on vaccine administration
With the recent focus on vaccines following the introduction of Covid-19 vaccines, CMS is taking a renewed focus on the issue while acknowledging payments for mass immunizers and administering most preventative vaccines have been cut by about 30% in recent years.
More specifically CMS is seeking information on:
- The different types of health care providers who furnish vaccines and how have those providers changed since the start of the pandemic.
- How the costs of furnishing flu, pneumococcal, and hepatitis B vaccines compare to the costs of furnishing COVID-19 vaccines, and how costs may vary for different types of health care providers.
- How the COVID-19 PHE may have impacted costs, and whether health care providers envision these costs to continue.
Additionally, following the recent change to boost payment for administering Covid-19 vaccines in a home setting, CMS is also requesting feedback on what providers feel should qualify as a “home.”
Specimen collection fees
In a related issue, CMS is also seeking feedback on Clinical Laboratory Fee Schedule (CLFS) reimbursement levels for specimen collection for homebound patients. During the Covid-19 PHE, CMS boosted payments to independent laboratories for Covid-19 specimen collection from beneficiaries who are homebound or inpatients not in a hospital from $3-5 to $23-25.
While the agency said it anticipates lowering that rate once the PHE expires, they are now seeking comment on appropriate reimbursement for sending trained personnel to collect specimens, including travel costs.