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2021 CMS Proposed Medicare Physician Fee Schedule Released

  • Director of Anatomic Pathology Development

On August 4, 2020 CMS released its 2021 proposed physician fee schedule. Unfortunately, under the proposed schedule, pathology and several other specialties would take the brunt of some significant reductions. This is largely the result of the redistributive effects of previously finalized changes to the office/outpatient E/M visits taking effect in 2021. The results of these reductions will have a noticeable impact on pathology practices nationwide, further diminishing the already narrow margins groups operate under today. These reductions include, but are not limited to:

Cytopathology takes the largest hit with 22% reductions to the 88141, G0124, and G0141. The 88305, which has already experienced significant cuts in previous years, will see a 12% reduction on the professional component (no impact to the technical component). Similarly, other high-volume pathology codes 88342/88341 take the same reduction on the professional, but also see a 4% reduction on the technical.

In addition to these proposed fees impacting Medicare claims, these changes will also impact any commercial payor contract tied to current year Medicare. Further, it was recently announced Cigna is adopting CMS’s G0416 policies for billing prostates. In addition to the initial reduction in revenue received from a G0416 vs billing individual 88305s, Cigna contracts tied to current year Medicare fee schedules will experience a decrease of 5% for the global and 11% for the professional. A slight increase of 3% would be realized on the technical component.

Practices billing all, or heavier volumes of, Professional Component would experience the most significant reduction in revenue, however, independent labs can still anticipate to take about a 5% hit Already struggling laboratories will further feel the intensifying pressure of lower margins, at a time when COVID leaves us full of unknowns. Pathologists will have to make difficult decisions on how their practice will look tomorrow, next week, next year. Now is not the time for complacency. It’s critical groups understand what their COST of performing individual tests are and how these continued cuts impact their ability to be profitable. Tangible data, including the compilation of critical cost information, is necessary in order to fight back on CMS’s reductions – reductions that will inevitably fall below cost, if they haven’t already, if not monitored or reported. It is not enough to expect only the institutions and organizations representing pathology practices to fight these changes. Pathologists and their administrative teams have incredible stories to tell and at this point should be screaming them from the rooftops (backed up by data, of course). If you’d like to provide comments or feedback regarding these cuts, you can reach out to the CAP or directly to CMS using the link below.

You can view the 2021 proposed rule impact table that College of American Pathologists (CAP) developed, here:

CMS will accept comments on the proposed rule until October 5, 2020, and will respond to comments in a final rule. The proposed rule can be downloaded from the Federal Register at:

If you have any questions regarding these impacts, please contact Diana Richard, XIFIN’s Director of Anatomic Pathology Program Development, at

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