Pathology/Lab Coding Alert

Comment on CLFS revaluation process too.

CMS recently released the proposed rule for the 2018 Medicare Physician Fee Schedule, and the word is that you should expect some ups and downs for your pathology pay next year.

Good news: The proposed conversion factor (multiplier for procedure RVUs, or relative value units) doesn’t change much in 2018 — up to 35.9903 compared to 35.8887 for 2017.

Bad news: But CMS states in the proposed rule that payment for pathology services across the board will decline by one percent, while overall payment for clinical laboratories will decrease by two percent next year.

Caveat: Of course, how much your payment actually changes will depend on what services/volumes your lab performs. Read on to learn which services will see the largest increases and decreases in pay.

See What’s Looking Up

The 2018 proposed rule significantly increases technical component pay for certain services, such as forensic cytopathology (88125-TC, 55 percent increase) cell marker study (88182-TC, 12 percent increase), and each additional histochemical stain (88314-TC, 11 percent increase)

If your lab performs certain apheresis procedures, you can expect a pay increase ranging from 3 percent for 36516 (Therapeutic apheresis; with extracorporeal selective adsorption or selective filtration and plasma reinfusion) to 73 percent for 36522 (Photopheresis, extracorporeal).

See What’s Looking Down

Pay for flow cytometry will decline in 2018, from a -1 percent to a -19 percent update for various codes (88184-88189, Flow cytometry ….).

You’ll also see a 19 percent decline in pay for 88323-TC (Consultation and report on referred material requiring preparation of slides, technical component), 88333-TC (Pathology consultation during surgery; cytologic examination [eg, touch prep, squash prep], initial site, technical component), and 88355-TC (Morphometric analysis; skeletal muscle, technical component).

Also expect a 19 percent decrease in pay for the professional component of 88360-26 (Morphometric analysis, tumor immunohistochemistry (eg, Her-2/neu, estrogen receptor/progesterone receptor), quantitative or semiquantitative, per specimen, each single antibody stain procedure; manual, professional component) and 88361-26 (…using computer-assisted technology, professional component)

Please Comment on CLFS Reporting Process

Although this is the MPFS proposed rule, Medicare put the following in the “other provisions” section: “Solicitation of Public Comments on Initial Data Collection and Reporting Periods for Clinical Laboratory Fee Schedule” (CLFS).

If yours was an “applicable lab” that was required to provide your lab’s volume and payment data for lab services paid under the CLFS during the reporting period January 1, through March 31, 2017 (with extended non-penalty period), CMS wants to know about your reporting experience. Specifically, some of the questions the agency asks are as follows:

• Was the CMS data reporting system easy to use?
• Was the data you were required to report readily available in your record systems?
• Did you contact the Help Desk or CLFS Inquiries Mailbox, and if so, what was your experience?
• How much time (hours) was required to assemble and report applicable information to CMS?

And more: Keep watching Pathology/Lab Coding Alert for more info on how the MPFS proposed rule, and later in the fall, the final rule, might impact your lab.

Resource: You can access the MPFS proposed rule in the July 21, 2017 Federal Register at www.federalregister.gov/documents/2017/07/21/2017-14639/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions.