How the Final 2018 Medicare Fee Schedule Affects Your Pay. Donald Karcher, MD, FCAP W. Stephen Black-Schaffer, MD, FCAP Jonathan L.
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1 How the Final 2018 Medicare Fee Schedule Affects Your Pay Donald Karcher, MD, FCAP W. Stephen Black-Schaffer, MD, FCAP Jonathan L. Myles, MD, FCAP November 9, 2017
2 Welcome Donald Karcher, MD, FCAP Chair, CAP Council on Government and Professional Affairs 2017 College of American Pathologists. All rights reserved. 2
3 Welcome W. Stephen Black-Schaffer, MD, FCAP Chair, CAP Economic Affairs Committee 2017 College of American Pathologists. All rights reserved. 3
4 Welcome Jonathan L. Myles, MD, FCAP Member, CAP Board of Governors Former Pathology Advisor to the AMA-RUC 2017 College of American Pathologists. All rights reserved. 4
5 Final 2018 Medicare Physician Fee Schedule Final 2018 Medicare Physician Fee Schedule was released on November 2 CAP members received a STATLINE Alert with initial analysis of this final ruling CAP will continue to engage with the Centers for Medicare & Medicaid Services (CMS) 2017 College of American Pathologists. All rights reserved. 5
6 Agenda CAP Policy and Advocacy Final 2018 Fee Schedule and Reimbursement Policy Overview Specific Pathology Reimbursement Changes Laboratory Date of Service Policy: 14-Day Rule Changes to Physician Quality Reporting System (PQRS) and Value-Based Modifier Questions 2017 College of American Pathologists. All rights reserved. 6
7 CAP Policy and Advocacy 2017 College of American Pathologists. All rights reserved. 7
8 CAP s Policy and Advocacy Agenda Protect the value of pathology services Ensure pathologists can adapt to new payment models Sustain a favorable laboratory regulatory environment 2017 College of American Pathologists. All rights reserved.
9 47% of pathology CPT codes have been targeted by CMS since College of American Pathologists. All rights reserved. 9
10 CAP Advocacy on Medicare Payment CAP continues to work with the CMS on Medicare reimbursement: Advocating directly to the CMS throughout the year through face-to-face meetings Via the CAP s seat at the AMA/Specialty Society Relative Value Update Committee (RUC) Submitting formal comments on fee schedules and other Medicare regulations 2017 College of American Pathologists. All rights reserved. 10
11 Final 2018 Fee Schedule and Reimbursement Policy Overview 2016 College of American Pathologists. All rights reserved. 11
12 Final Payment for Pathology Services CY 2018 Specialty Allowed Charges (millions) Work RVU Impact Change Combined Work + PE Impact Pathology $1,154 ~0% -1% Independent Laboratory $690 ~0% -1% Reflects averages by specialty (based on Medicare utilization) The impact depends on mix of services and payers (Medicare and non-medicare) Physicians receive pay from other Medicare payment systems 2017 College of American Pathologists. All rights reserved. 12
13 CMS Accepts CAP s Recommendations Therapeutic Apheresis Services CMS accepted the CAP s recommended increases to the physician work relative values (RVUs) for six therapeutic apheresis codes Identified the apheresis codes as potentially misvalued in the CY 2016 PFS proposed rule The CAP worked with the specialists to develop recommendations that were presented to the AMA RUC: American Society for Apheresis Renal Physicians Association American Society of Hematology 2017 College of American Pathologists. All rights reserved.
14 CMS Accepts CAP s Recommendations Therapeutic Apheresis Services CPT Code Description 2017 College of American Pathologists. All rights reserved. Work RVU 2017 Work RVU 2018 % Change Therapeutic apheresis; for white % blood cells Therapeutic apheresis; for red % blood cells Therapeutic apheresis; for % platelets Therapeutic apheresis; for % plasmapheresis Therapeutic apheresis; with % extracorporeal selective adsorption or selective filtration and plasma reinfusion Photopheresis, extracorporeal %
15 Pathology Consultation During Surgery Codes The CMS identified pathology consultation during surgery CPT codes and in the 2014 proposed fee schedule as potentially misvalued The CAP performed a physician work survey and defended the codes before the AMA RUC and recommend maintaining the current physician work RVUs CPT Code Description Pathology consultation during surgery; cytologic examination (eg, touch prep, squash prep), initial site Pathology consultation during surgery; cytologic examination (eg, touch prep, squash prep), each additional site (List separately in addition to code for primary procedure) 2017 Work RVU 2018 Work RVU % Change % % 2017 College of American Pathologists. All rights reserved.
16 Payment for Tumor Immunohistochemistry CPT 2017 Work 2018 Work % % Code MOD Description RVU RVU Change Payment Payment Change Tumor % $57.42 $ % immunohistochem/manual TC Tumor % $84.70 $ % immunohistochem/manual Tumor % $ $ % immunohistochem/manual Tumor % $61.01 $ % immunohistochem/comput TC Tumor % $95.82 $ % immunohistochem/comput Tumor % $ $ % immunohistochem/comput Immunohisto antb 1 st stain % $37.32 $ % TC Immunohisto antb 1 st stain % $71.06 $ % Immunohisto antb 1 st stain % $ $ % 2017 College of American Pathologists. All rights reserved. 16
17 Diagnostic Bone Marrow Aspiration and Biopsy Services In the proposed ruling for 2016, CMS identified diagnostic bone marrow biopsy CPT code as a potentially misvalued service. Prior to survey, the CPT structure was changed to improve nomenclature for these codes (i.e. diagnostic vs. therapeutic use). The descriptors for CPT codes and were revised and new code was created to reflect changes in practice patterns that are now available College of American Pathologists. All rights reserved.
18 Diagnostic Bone Marrow Aspiration and Biopsy Services CPT Code Description Diagnostic bone marrow; aspiration(s) Diagnostic bone marrow; biopsy(ies) N Diagnostic bone marrow; biopsy(ies) and aspiration(s) G0364 Bone marrow aspiration performed with bone marrow biopsy through the same incision on the same date of service due N New codes for CY Work RVU 2018 Work RVU % Change % % NA 1.44 NA 0.16 Deleted HCPCS Code 2017 College of American Pathologists. All rights reserved.
19 Payment for Flow Cytometry Medicare Payment Percent Change CPT Code Description Proposed 2018 Final P F Flowcytometry/ tc 1 marker $94.51 $76.26 $61.73 $61.18 $ % 10% Flowcytometry/tc add-on $57.49 $46.55 $37.68 $30.59 $ % -19%* Flowcytometry/read 2-8 $72.59 $73.04 $59.22 $48.23 $ % -19%* Flowcytometry/read 9-15 $92.35 $93.09 $75.37 $66.22 $ % -12% Flowcytometry/read 16 & > $ $ $92.59 $88.54 $ % - 4% Note that codes and are projected to be reduced in subsequent years, due to a 19% reduction cap. The CAP continues to advocate for appropriate reimbursement for these services College of American Pathologists. All rights reserved. 19
20 Final 2018 Hospital Outpatient Prospective Payment System Rule Laboratory Date of Service (DOS) Policy 14 Day Rule 2017 College of American Pathologists. All rights reserved. 20
21 CMS Altered its 14-Day Rule Policy The CAP argued for this change in comments to CMS The CAP also worked with ASCO and the AMA to present a united effort urging CMS to change its 14 day rule policy CMS agreed to alter its 14 day rule policy for advanced diagnostic laboratory tests (ADLTs) and molecular pathology tests on specimens obtained in outpatient setting College of American Pathologists. All rights reserved.
22 CMS Altered its 14-Day Rule Policy Additional exception added to DOS regulations: Permits laboratories to bill Medicare directly for ADLTs and molecular pathology tests For these services, the DOS is the date the test was performed (instead of the date of collection) 2017 College of American Pathologists. All rights reserved.
23 Other Medicare Program Adjustments to Reimbursement in 2018 Changes to Physician Quality Reporting System and Value-Based Modifier 2017 College of American Pathologists. All rights reserved. 23
24 Changes to Physician Quality Reporting System and Value-Based Modifier Changes to current Physician Quality Reporting System (PQRS) reporting requirements Change from 9 measures to 6 measures Reduction in Value-Based Modifier penalties to align with the new Merit-based Incentive Payment System (MIPS) 2017 College of American Pathologists. All rights reserved. 24
25 Before we take questions 2017 College of American Pathologists. All rights reserved. 25
26 MACRA Webinar On November 29 at 1 pm ET/ 12 pm CT, the CAP will host a webinar analyzing the final 2018 Quality Payment Program regulation The Pathologists Quality Registry, the CAP s very own QCDR, is available for 2018 QPP Reporting Enrollment College of American Pathologists. All rights reserved. 26
27 Save This Date 2018 CAP Policy Meeting April 30 May 2 Washington Marriott, Washington, DC 2017 College of American Pathologists. All rights reserved.
28 Stay Informed Through the CAP Follow CAP on social media o o Facebook.com/capathologists Visit CAP.org > advocacy Read STATLINE Join PathNET, the CAP s grassroots advocacy network 2017 College of American Pathologists. All rights reserved. 28
29 Questions 2017 College of American Pathologists. All rights reserved. 29
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