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The CAP has strong concerns about a Government Accountability Office (GAO) report that evaluates new Medicare payment rates for clinical laboratory services as mandated under reforms required by the Protecting Access to Medicare Act (PAMA).

In the November 30 report, the GAO raised the possibility that implementation of the new Medicare clinical laboratory rates could cost the Centers for Medicare & Medicaid Services (CMS) an extra $11 billion unnecessarily. The GAO made three recommendations that, in their opinion, will prevent Medicare from paying more than is necessary.

The CAP and other stakeholders have expressed strong concerns over two of these recommendations, as they are significantly flawed and would not result in the Medicare savings as predicted by GAO. In the report, the GAO recommended that the CMS should:

  1. Collect complete private-payer data from all laboratories required to report or address the estimated effects of incomplete data. The CAP agrees with this recommendation, as the CAP has continually argued that underrepresentation of many laboratory types results in a skewing of the PAMA payment rates.
  2. Phase in payment-rate reductions that start from the actual payment rates rather than the maximum payment rates Medicare paid before 2018. The CAP disagrees with this recommendation as the already-taken action was appropriate and more extreme cuts would threaten the ability of laboratories to provide services to Medicare beneficiaries.
  3. Use bundled rates for panel tests. The CAP strongly disagrees with assertions under this recommendation. The GAO estimate for increased expenditures due to changes in bundled rates depends on all panel tests, with or without billing codes, being unbundled and billed as individual component tests by every laboratory. Further, laboratories have not changed their billing practices and moved away from billing panels because of PAMA.

The CAP and other key stakeholders are communicating their position on these recommendations to key decisionmakers, challenging assumptions that they would result in the Medicare savings, as the GAO report predicts. The CAP will continue to advocate for a legislative fix to PAMA to ensure quality patient care and access to testing.

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The CMS posted a preview of updated physician quality data, including those from eligible pathologists participating in MIPS for 2017, on the Physician Compare website. Pathologists, as well as other eligible clinicians, have until December 31, 2018, at 8 PM ET (5 PM PT) to preview their 2017 Quality Payment Program performance information before it appears in early 2019. 

Pathologists can access the secured preview through the QPP website by logging on using your Enterprise Identity Management (EIDM) credentials. If you do not have an EIDM account, refer to this guide. The CAP recommends that eligible pathologists log in and review their profiles, including their 2017 QPP data, to ensure all data is correct.

Per the Quality Payment Program regulations, 2017 Quality Payment Program performance data are available for public reporting on Physician Compare. Performance data submitted under MIPS and Advanced Payment Models (APMs) are available for public reporting. The Physician Compare website will link clinicians and groups to APM profile pages for selected Advanced APMs and Shared Savings Program Track 1 ACOs. For MIPS, a subset of the quality measures data will be publicly reported as well as improvement activity (IA) performance. However, for pathologists, none of the pathology related measures are in the subset and the IA performance will not be posted until 2019.

The CMS also has resources on how to preview your data

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Reports for performance in the 2016 Physician Quality Reporting System (PQRS) will only be available to download from the CMS until December 31.

A pathologist can access his or her PQRS feedback report and The Quality and Resource Use Report through a CMS portal, which requires using an Enterprise Identity Management system account. The CMS has additional instructions on signing up for an account and accessing the reports on its website.

The Quality Payment Program’s MIPS reporting track replaced the PQRS program.

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Emily E. Volk, MD, FCAP

As part of our ongoing commitment to ensure pathologists can successfully participate in new and evolving payment models, the CAP continues to offer MIPS educational webinars. All MIPS webinars are available for download

The final webinar in our Decoding MIPS series is open for registration, Steps to Take Before Reporting MIPS Data, and will take place on January 8, 2019, at 3 PM ET. During the webinar, Emily Volk, MD, MBA, FCAP, will ways of maximizing your scoring for 2018 before submitting results to CMS. Register today.

The previous webinar, Quality Measures that Will Improve Your MIPS Score, where Diana Cardona, MD, FCAP, reviewed the specific quality measures that can help pathologists score the most points for their 2018 MIPS score, is now available for download.

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An accurate diagnosis is perhaps the most critical factor in effective patient care. No one knows this more than you. Connect with and educate legislators and policy experts on the value that pathology brings to the health care continuum.

Register and join us at the:

2019 Policy Meeting
April 29—May 1
Marriott Metro Center, Washington, DC

Make pathology’s impact on patient care heard in Washington.

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