Pathology/Lab Coding Alert

Changes from proposed rule help pathologists.

A slight Conversion Factor (CF) increase could be good news for some physicians (from $35.8043 in 2016 to $35.8887 for 2017), but Relative Value Unit (RVU) changes easily override that bonus for many specialties.

Parse the MPFS by Specialty

Compared to other specialties, how can you expect your pathology practice or independent lab to make out based on the 2017 Medicare Physician Fee Schedule (MPFS) final rule?

Losers: The MPFS that went into effect Jan. 1 shows an expected 1 percent decrease for pathology practices, and a 5 percent decrease for independent labs. Reductions in direct Practice Expense (PE) inputs, such as lab supplies, account for much of the reduction in RVUs for pathology services.

Winners: Meanwhile, CMS continues to emphasize primary care in coverage and payment strategies, increasing payment on the 2017 MPFS for specialties such as family practice and internal medicine. “By better valuing primary care, care coordination and prevention, we help people access the services they need to stay well,” according to Andy Slavitt, CMS acting administrator and Patrick Conway, MD, MSc, CMS acting principal deputy administrator and chief medical officer, in a blog post about the MPFS Final Rule

More praise: In a press release responding to the final rule, Andrew W. Gurman MD, AMA president stated, “This annual policy fine-tuning is an opportunity for CMS to improve treatment options for patients and streamline bureaucratic demands on physicians.”

If that doesn’t help you feel better about your lab’s outlook, read on to find a silver lining.

Roll Back ‘Add-on’ Discounts

Indeed, the news is not all bad for pathology. Thanks to advocacy by stakeholders such as the College of American Pathologists (CAP) and the American Society for Clinical Pathology (ASCP), pathologists can expect a little bit more pay for “add-on” services for certain procedures in 2017.

Specifically, additional immunohistochemistry, immunofluorescence, and in situ hybridization services were undervalued, according to industry experts. CMS agreed to increase the value of the following pathology add-on codes by reducing their previous “discount from the parent code” to 20 percent, rather than the prior 25 percent:

• +88350 — Immunofluorescence, per specimen; each additional single antibody stain procedure (List separately in addition to code for primary procedure)
• +88341 — Immunohistochemistry or immunocytochemistry, per specimen; each additional single antibody stain procedure (List separately in addition to code for primary procedure)
• +88364 — In situ hybridization (e.g., FISH), per specimen; each additional single probe stain procedure (List separately in addition to code for primary procedure)
• +88369 — Morphometric analysis, in situ hybridization (quantitative or semi-quantitative), manual, per specimen; each additional single probe stain procedure (List separately in addition to code for primary procedure)
• +88373 — Morphometric analysis, in situ hybridization (quantitative or semi-quantitative), using computer-assisted technology, per specimen; each additional single probe stain procedure (List separately in addition to code for primary procedure).

Pay difference: Looking at Table 1 on page 12, you can see how pay for some of these codes has increased in 2017 (although PE rollbacks confounded some of the gains). Still, according to CAP analysis, based on historical test volume, pathologists stand to earn over $4 million more from these services in 2017 due to this policy change. (www.captodayonline.com/medicare-revises-2017-discount-add-codes-increases-professional-cuts-technical-pay-prostate-biopsies/)

Observe Prostate Biopsy Difference

After years of changing how the agency pays for prostate/prostate saturation biopsies, CMS settled in 2015 on a single code, G0416 (Surgical pathology, gross and microscopic examinations, for prostate needle biopsy, any method) to describe all prostate biopsy specimen exams regardless of the specimen number or surgical technique used to obtain the tissue.

After industry experts requested an increase in pay for the physician work, CMS agreed to boost that component in 2017 from 3.09 to 3.60 RVUs, or a 17 percent increase.

But as with some other codes, the practice expense roll-back for items such as lab supplies resulted in a net pay reduction for G0416. Specifically, CMS reduced the non-facility practice expense RVUs from 11.72 in 2016 to 9.97 in 2017, which makes for a net reimbursement reduction of 8.19 percent for prostate biopsy exams this year.

Look for Slide Consult Changes

You can also expect a pay increase this year when your pathologist performs pathology slide consultations, especially the comprehensive exam, as described by the following codes:

• 88321 — Consultation and report on referred slides prepared elsewhere
• 88323 — Consultation and report on referred material requiring preparation of slides
• 88325 — Consultation, comprehensive, with review of records and specimens, with report on referred material.

CMS agreed with commentators to hold the line on the physician work and PE components of these services, and even to increase the work RVUs for 88325 by 14 percent.

Check Out Flow Cytometry Pay Update

Having identified the need to reduce pay for flow cytometry as part of its “misvalued code” initiative, you can expect steep cuts to the following codes in 2017:

• 88184-+88185 — Flow cytometry, cell surface, cytoplasmic, or nuclear marker, technical component only …
• 88187-88189 — Flow cytometry, interpretation …

In particular, you can expect a reduction by more than 20 percent for the physician work component of each of the interpretation codes 88187, 88188, and 88189.

Expect Practice Expense Reductions for Eosin Stain

With CMS claiming that reduced costs for eosin stain supplies justifies large technical component pay reductions for numerous pathology codes, you can expect to take in less pay for surgical pathology codes 88302-88309 (…Surgical pathology, gross and microscopic examination …), cytopathology codes 88104-88112 (Cytopathology … except cervical or vaginal…), as well as several of the codes already mentioned (such as slide consults).

To see the RVU change for these and other codes discussed in this article, look to Table 1 on page 12 for a 2016 to 2017 comparison. Then you can take this data, along with your lab’s test mix, and get an idea of how the 2017 MPFS update might specifically affect your 2017 pay.