Pathology/Lab Coding Alert

Pap interpretation takes big hit.

Changes are coming down the pike for payment on some high-volume pathology services beginning in January, according to the 2020 Medicare Physician Fee Schedule (MPFS) final rule.

Background: The reason for many 2020 MPFS changes is to “[free] up clinicians to focus on their patients rather than on paperwork,” says HHS Secretary Alex Azar in a press release for the final rule.

“Clinician burnout is high because outdated government regulations are diverting their attention from what matters: patient care,” affirms CMS Administrator Seema Verma in the press release.

That’s the official view of the rule, but read on to see how our experts drill down to the real impact for your pathology lab.

Learn Systemic Changes

CMS published the CY 2020 MPFS in the Federal Register on Nov. 15, and the first fact you need to know is the update to the conversion factor.

Details: The budget-neutral adjustment bumps the conversion factor (CF) up to $36.09, an increase of five cents from the CY 2019 amount of $36.04.

Reminder: MPFS “payments are based on the relative resources — relative value units [RVUs] — required to furnish services, with the conversion factor applied,” counsels attorney Elizabeth N. Swayne with King & Spalding LLP, in online analysis in the Health Headlines newsletter. “CMS also finalized technical improvements related to practice expenses and refinements to standard rates to reflect premium data involving malpractice expense and geographic practice cost indices.”

Focus on Pathology Code Changes

You can see what pay your lab can expect in 2020 by multiplying the CF by a code’s RVUs, which is the total of physician work, practice overhead, and malpractice expense. You’ll also need to apply any regional adjustment to calculate your pay.

Little change: Don’t expect the small CF increase to provide much pay gain for your lab. Accounting for the CF increase and individual-code RVU changes, CMS estimates that the 2020 MPFS will result in a 1 percent increase for independent labs and no change in overall pay for pathology practices.

Caveat: The actual payment impact for your specific lab could vary from those projections depending on the specific procedures and volumes you perform. Also remember that the MPFS doesn’t account for clinical lab services, which Medicare pays on the Clinical Laboratory Fee Schedule (CLFS).

Study the following table to see codes that will have MPFS payment changes of at least 10 percent increase or decrease this year.

*National non-facility amount, CF $36.0896
+National non-facility amount, CF 36.0391

Check TC changes: You’ll notice in the table that many of the payment increases involve the technical component (TC) of pathology procedures. The TC pay change in turn impacts the global fee. For instance, the 23 percent pay boost to 88346-TC that you see in the table results in a global-fee boost of 13 percent, while the G0416-TC 19 percent pay decrease results in a global fee 10 percent loss.

Hit again: Many of the codes that show large price changes for 2020 had already changed significantly in 2019, such as the following codes:

• +88185 – 19 percent pay cut in 2019; 10 percent decrease in 2020
• 88319-TC – 32 percent increase in 2019; 20 percent boost in 2020
• 88346-TC – 28 percent increase in 2019; 23 percent boost in 2020
• 88381-TC – 32 percent increase in 2019; 21 percent boost in 2020
• G0416-TC – 19 percent pay cut in 2019; 19 percent decrease in 2020

Focus on Pap interpretation: The 2020 MPFS shows a 19 percent pay decrease for every Pap interpretation code, whether CPT^® or HCPCS Level II.

“If an initial Pap test demonstrates an abnormality, then a pathologist will evaluate the slides and assign a diagnosis based on the findings,” explains says R.M. Stainton Jr., MD, president of Doctors’ Anatomic Pathology Services in Jonesboro, Ark. The pathologist’s interpretation earns one of the following codes, depending on the code for the initial procedure, as follows:

• 88141 (Cytopathology, cervical or vaginal (any reporting system), requiring interpretation by physician). Use with any of the CPT^® screening codes: 88142-88153, 88164-88167, 88174-88175.
• G0141 (Screening cytopathology smears, cervical or vaginal, performed by automated system, with manual rescreening, requiring interpretation by physician). Use with screening codes G0147 and G0148.
• G0124 (Screening cytopathology, cervical or vaginal (any reporting system), collected in preservative fluid, automated thin layer preparation, requiring interpretation by physician). Use with screening codes G0123 or G0143-G0145.
• P3001 (Screening Papanicolaou smear, cervical or vaginal, up to three smears, requiring interpretation by physician). Use with screening code P3000.

You can see from the table that the payment for each of these codes changes from $32.44 in 2019 to $26.35 in 2020.

See New ‘Sign and Date’ Policy Logistics

To better align with its Patients Over Paperwork mantra, CMS followed through and modified its documentation policy with a new “sign and date” update.

“CMS established a general principle to allow the physician, the physician assistant (PA) or the advanced practice registered nurse (APRN) who furnishes and bills for their professional services to review and verify, rather than re-document, information included in the medical record by physicians, residents, nurses, students or other members of the medical team,” says Miranda Franco, senior policy advisor with Holland & Knight LLP in Washington D.C., in the Holland & Knight Healthcare Blog. “This principle would be applied across the spectrum of all Medicare-covered services paid under the MPFS.”

Resource: Read the final rule at  www.federalregister.gov/documents/2019/11/15/2019-24086/medicare-program-cy-2020-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other.

If you want to comment on the CY 2020 MPFS, you have until Dec. 31 to do so.