Medicare 2014 Physician Fee Schedule Resource Center

Updated August 14, 2013

2014 Proposed Medicare Physician Fee Schedule Cuts Payment for Pathology TC and Global Payments

The Centers for Medicare and Medicaid Services (CMS) has proposed linking payment for over 200 services to hospital outpatient rates as part of its "misvalued code" initiative. If finalized as proposed, it will reduce the technical component (TC) and global payment of 40 pathology services billed for non-hospital patients by as little as 4% and as much as 80% depending on the services.

CAP Actions

In the coming weeks CAP will be meeting with CMS and the White House to lay out our specific concerns. In addition, we will be submitting a formal comment letter to CMS. CAP is also engaging with the AMA and other affected organizations to strengthen our response efforts. As the Congress considers legislation to repeal the Sustainable Growth Rate (SGR), CAP is engaged in finding alternative ways for pathologists to meet quality and pay for performance requirements.

CAP's Position

• CAP opposes this new round of cuts to pathologists and pathology practices.
• CMS' proposal to link payment for pathology services to rates paid in the hospital outpatient prospective payment system is particularly concerning.
• The proposed policy fails to take into consideration the technical costs associated with specific individual codes.
• Further, it fails to recognize the distinct costs of physician services, which are required by law to be based on the resources required to perform the service.
• CAP supports the existing AMA-RUC process for valuing physician service codes. This process involves many stakeholders, including CAP.
• The AMA-RUC has shown itself to be accurate and fair, and has been thoroughly vetted over many years.
• CAP remains concerned about CMS' implementation of the Physician Quality Reporting System. CAP proposed three new quality measures for pathologists, which CMS rejected.

How You Can Help

• Your help will be crucial in fighting these proposed cuts. A sixty-day comment period is underway. CAP is analyzing data pertaining to the proposed rule and will provide additional information to you for formulating your individual comments to CMS. You can help by writing comments to CMS before the September 6 deadline.
• To submit comments
  1. Go to www.Regulations.gov
  2. Go to search and type in RIN: 0938-AR56
  3. Click on the comment now button (then make your comment)

Proposed Rule Impact Chart

2014 Proposed Rule Impact Chart Per Code
(Excel, 176 KB)

CAP Advocacy Resources

CAP Advocacy Action Alert, August 6, 2013 (PDF, 153 KB)
Issue Brief: Medicare Payment for Pathology Services, (PDF, 131 KB)
Letter opposing the physician fee schedule cuts and asking Congress to intervene signed by major pathology organizations and state pathology societies July 31, 2013 (PDF, 18 KB)
CAP Advocacy Action Alert, July 30, 2013 (PDF, 104 KB)
CAP Advocacy Action Alert, July 19, 2013

Federal Register Links

• 2014 PFS Proposed Rule
• CMS Fact Sheet
• CMS PQRS Fact Sheet

CAP News Coverage and Alerts on Final Rule

• CAP Calls on CMS to Further Examine Pathology Payment Methodology, Statline Alert, July 22, 2013
• 2014 Physician Fee Schedule Proposed Rule Targets Misvalued Codes, Statline, July 19, 2013
• Proposed 2014 Physician Fee Schedule Includes More Cuts for Docs, Statline Alert, July 9, 2013

Webinars

Register now for an exclusive CAP webinar on proposed 2014 PFS: Understanding the 2014 Proposed Medicare Physician Fee Schedule

Date & Time
Wednesday, August 7, 2013 at 3:00 – 4:30 PM. Eastern Time.

Speakers

• Jonathan Myles, MD, FCAP, chair of CAP's economic affairs committee
• Dr. Emily Volk, chair of CAP's quality reporting work group