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 Code | Service | Proposed 2021 | Current 2020 | % Change |
| 88112 – Global | Cytopath cell enhance tech | $63.55 | $68.57 | -7.3% |
| 88112 – TC | Cytopath cell enhance tech | $38.07 | $39.70 | -4.1% |
| 88112 – 26 | Cytopath cell enhance tech | $25.49 | $28.87 | -11.7% |
| 88120 – Global | Cytp urne 3-5 probes ea spec | $601.97 | $589.34 | 2.1% |
| 88120 – TC | Cytp urne 3-5 probes ea spec | $548.10 | $529.07 | 3.6% |
| 88120 – 26 | Cytp urne 3-5 probes ea spec | $53.87 | $60.27 | -10.6% |
| 88121 – Global | Cytp urine 3-5 probes cmptr | $433.25 | $450.40 | -3.8% |
| 88121 – TC | Cytp urine 3-5 probes cmptr | $388.73 | $399.51 | -2.7% |
| 88121 – 26 | Cytp urine 3-5 probes cmptr | $44.52 | $50.89 | -12.5% |
| 88184 | Flowcytometry/ 1st marker | $66.78 | $68.21 | -2.1% |
| 88185 | Flowcytometry/ additional marker | $21.94 | $22.38 | -2.0% |
| 88187 | Flowcytometry/read 2-8 | $33.87 | $39.34 | -13.9% |
| 88188 | Flowcytometry/read 9-15 | $58.71 | $66.04 | -11.1% |
| 88189 | Flowcytometry/ read 16+ | $78.39 | $88.78 | -11.7% |
| 88305- Global | Tissue exam by pathologist | $66.78 | $71.46 | -6.5% |
| 88305 – TC | Tissue exam by pathologist | $32.26 | $32.12 | 0.4% |
| 88305 – 26 | Tissue exam by pathologist | $34.52 | $39.34 | -12.3% |
| 88307 – Global | Level V, tissue exam by pathologist | $271.95 | $281.50 | -3.4% |
| 88307 – TC | Level V, tissue exam by pathologist | $195.82 | $194.88 | 0.5% |
| 88307 – 26 | Level V, tissue exam by pathologist | $76.13 | $86.62 | -12.1% |
| 88309 – Global | Tissue exam by pathologist | $412.93 | $427.66 | -3.4% |
| 88309 – TC | Tissue exam by pathologist | $278.40 | $275.00 | 1.2% |
| 88309 – 26 | Tissue exam by pathologist | $134.52 | $152.66 | -11.9% |
| 88312 – Global | Special stains group 1 | $106.14 | $107.19 | -1.0% |
| 88312 – TC | Special stains group 1 | $81.62 | $79.40 | 2.8% |
| 88312 – 26 | Special stains group 1 | $24.52 | $27.79 | -11.8% |
| 88313 – Global | Special stains group 2 | $77.10 | $77.23 | -0.2% |
| 88313 – TC | Special stains group 2 | $65.81 | $64.60 | 1.9% |
| 88313 – 26 | Special stains group 2 | $11.29 | $12.63 | -10.6% |
| 88341 – Global | Immunohistochemistry (add stain) | $88.07 | $94.19 | -6.5% |
| 88341 – TC | Immunohistochemistry (add stain) | $61.94 | $64.60 | -4.1% |
| 88341 – 26 | Immunohistochemistry (add stain) | $26.13 | $29.59 | -11.7% |
| 88367 – Global | Insitu hybridization auto | $109.68 | $115.13 | -4.7% |
| 88367 – TC | Insitu hybridization auto | $78.39 | $79.40 | -1.3% |
| 88367 – 26 | Insitu hybridization auto | $31.29 | $35.73 | -12.4% |
| 88368 – Global | Insitu hybridization manual | $129.36 | $133.89 | -3.4% |
| 88368 – TC | Insitu hybridization manual | $91.30 | $90.58 | 0.8% |
| 88368 – 26 | Insitu hybridization manual | $38.06 | $43.31 | -12.1% |
| G0416 – Global | Prostate biopsy | $331.31 | $347.90 | -4.8% |
| G0416 – TC | Prostate biopsy | $166.46 | $162.40 | 2.5% |
| G0416 – 26 | Prostate biopsy | $164.85 | $185.50 | -11.1% |