Proposed Medicare Physician Fee Schedule Contains a Mix of Good and Bad

The content of this article has been sourced from Volume 2, No. 9, September 2024 issue of the “Laboratory Economics Compliance & Policy Report” and is reprinted here with permission. Thank you to Laboratory Economics for granting us the right to share their valuable insights on this vital topic.

Although the proposed Medicare Physician Fee Schedule (MPFS) for 2025 does include cuts to physicians, including pathologists, it also contains some positive changes. The proposed MPFS, released July 10, would provide coverage for four new CAR T-cell services and increase the clinical labor rates for key laboratory clinical labor types. The College of American Pathologists (CAP) advocated for these changes.

The following are the new CAR T-cell services for which coverage was approved:

• HCPCS Code 3X018: Chimeric antigen receptor T-cell (CAR-T) therapy; harvesting of blood-derived T lymphocytes for development of genetically modified autologous CAR-T cells, per day (RUC work RVU of 1.94).
• HCPCS Code 3X019: Chimeric antigen receptor T-cell (CAR-T) therapy; preparation of blood-derived T lymphocytes for transportation (e.g., cryopreservation, storage) (RUC work RVU of 0.79).
• HCPCS Code 3X020: Chimeric antigen receptor T-cell (CAR-T) therapy; receipt and preparation of CAR-T cells for administration (RUC work RVU of 0.80).
• HCPCS Code 3X021: Chimeric antigen receptor T-cell (CAR-T) therapy, CAR-T cell administration, autologous.

To ensure that these services were appropriately valued, the CAP led a multispecialty effort to develop and present RVU recommendations at the September 2023 American Medical Association RUC meeting. The CAP supports the RVU recommendations proposed by CMS.

Cuts to Pathologists

Unfortunately, the proposed rule also would cut payments to physicians, including pathologists. The cuts stem largely from the expiration of two congressional Medicare pay relief packages that were intended to offset the previously finalized cuts in the 2023 and 2024 Medicare Physician Fee Schedules.

Under the proposed rule, pathology professional and technical payments would be cut by an average of 2.8% due to a reduction in the conversion factor, although reductions for some procedures could be cut by as much as 9%. The professional component of CPT 88305, tissue exam by pathologist, for example, would be cut by 3% to $34.94, while the technical component would be cut by 3% to $34.62.

The professional component of 88314, histochemical stains add-on, would be cut by 5% to $83.80, while the technical component would be cut by 6% to $65.04. The technical component of 88346, immunofluorescence, per specimen, initial antibody stain, would be cut by 7% to $107.42, while the professional component would be cut by 3% to $33.65. In only a few instances would payment increase. The technical component for CPT 88355, morphometric analysis, for example, would go up by 16% to $60.83, while the professional component would increase by 6% to $77.65. The CAP has published an impact table for the proposal, available here.

Quality Payment Changes

The proposed MPFS also includes six new Medicare Incentive Payment System (MIPS) Value Pathways (MVPs). The current MIPS performance threshold would be maintained, which would help prevent a MIPS penalty for CY 2024. The American Medical Association has urged Congress to make statutory changes to improve MIPS and address what it sees as fundamental problems with the program by reducing steep penalties that disproportionately hurt small and rural practices, prioritizing access to timely and actionable data, aligning MIPS with facility quality programs and incentivizing the development and reporting of new clinically relevant quality and cost measures.

Comments on the proposed MPFS are due Sept. 9, 2024.

Submit Comments

For additional insights, you can refer to our previous post titled “Call to Action for Healthcare Providers – Comment on the 2025 Proposed Physician Fee Schedule,” published on July 29, 2024.