Pathology services slated for 9% cut in 2021 MPFS Proposed Rule

August 4, 2020

Following a significant delay due to the COVID-19 Public Health Emergency, CMS issued the 2021 Medicare Physician Fee Schedule Proposed Rule Tuesday, Aug. 4. Unfortunately, the proposal shows that despite efforts from the College of American Pathologists and other provider advocates, pathology and independent lab services are still slated for substantial overall cuts to accommodate payment boosts for E/M services and maintain budget neutrality.

Overall, the rule shows pathology and independent lab services are scheduled to drop from 2020 rates by 9% and 5%, respectively.

Several significant codes are set to see reductions of 10% or more, primarily for the professional components. Notably, 88305-26 will be cut by 12.3% from $39.34 to $34.52. Flow cytometry reads for additional markers (88187-88189), another area that has been targeted in recent years, are also set to see cuts ranging from 11% to 13% of their 2020 rates.

The overall conversion factor will drop from $36.09 to $32.26, a reduction of roughly 11%. CMS stated the drop is required due to “the budget neutrality adjustment to account for changes in RVUs, as required by law.” Essentially, with significant boosts for E/M payments, cuts had to be made elsewhere to maintain budget neutrality.

As is evident in the chart below, there are not many silver linings for pathologists to fall back on.

Finalized rates are expected to be announced in the fall, with rate changes taking effect Jan. 1, 2021. For more information on specific rate updates, please refer to the chart below, or call us at 517-486-4262.

2021 MPFS proposed rates

CPT CodeServiceProposed 2021Current 2020% Change
88112 – GlobalCytopath cell enhance tech$63.55$68.57-7.3%
88112 – TCCytopath cell enhance tech$38.07$39.70-4.1%
88112 – 26Cytopath cell enhance tech$25.49$28.87-11.7%
88120 – GlobalCytp urne 3-5 probes ea spec$601.97$589.342.1%
88120 – TCCytp urne 3-5 probes ea spec$548.10$529.073.6%
88120 – 26Cytp urne 3-5 probes ea spec$53.87$60.27-10.6%
88121 – GlobalCytp urine 3-5 probes cmptr$433.25$450.40-3.8%
88121 – TCCytp urine 3-5 probes cmptr$388.73$399.51-2.7%
88121 – 26Cytp urine 3-5 probes cmptr$44.52$50.89-12.5%
88184Flowcytometry/ 1st marker$66.78$68.21-2.1%
88185Flowcytometry/ additional marker$21.94$22.38-2.0%
88187Flowcytometry/read 2-8$33.87$39.34-13.9%
88188Flowcytometry/read 9-15$58.71$66.04-11.1%
88189Flowcytometry/ read 16+$78.39$88.78-11.7%
88305- GlobalTissue exam by pathologist$66.78$71.46-6.5%
88305 – TCTissue exam by pathologist$32.26$32.120.4%
88305 – 26Tissue exam by pathologist$34.52$39.34-12.3%
88307 – Global Level V, tissue exam by pathologist$271.95$281.50-3.4%
88307 – TCLevel V, tissue exam by pathologist$195.82$194.880.5%
88307 – 26Level V, tissue exam by pathologist$76.13$86.62-12.1%
88309 – GlobalTissue exam by pathologist$412.93$427.66-3.4%
88309 – TCTissue exam by pathologist$278.40$275.001.2%
88309 – 26Tissue exam by pathologist$134.52$152.66-11.9%
88312 – GlobalSpecial stains group 1$106.14$107.19-1.0%
88312 – TCSpecial stains group 1$81.62$79.402.8%
88312 – 26Special stains group 1$24.52$27.79-11.8%
88313 – GlobalSpecial stains group 2$77.10$77.23-0.2%
88313 – TCSpecial stains group 2$65.81$64.601.9%
88313 – 26Special stains group 2$11.29$12.63-10.6%
88341 – GlobalImmunohistochemistry (add stain)$88.07$94.19-6.5%
88341 – TCImmunohistochemistry (add stain)$61.94$64.60-4.1%
88341 – 26Immunohistochemistry (add stain)$26.13$29.59-11.7%
88367 – GlobalInsitu hybridization auto$109.68$115.13-4.7%
88367 – TCInsitu hybridization auto$78.39$79.40-1.3%
88367 – 26Insitu hybridization auto$31.29$35.73-12.4%
88368 – GlobalInsitu hybridization manual$129.36$133.89-3.4%
88368 – TCInsitu hybridization manual$91.30$90.580.8%
88368 – 26Insitu hybridization manual$38.06$43.31-12.1%
G0416 – GlobalProstate biopsy$331.31$347.90-4.8%
G0416 – TCProstate biopsy$166.46$162.402.5%
G0416 – 26Prostate biopsy$164.85$185.50-11.1%
Source: 2021 MPFS Proposed Rule

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