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The CAP worked with the Centers for Medicare & Medicaid Services (CMS) to pull back drastic rule changes proposed last year to ensure that pathologists can participate in alternative payment models, including accountable care organizations (ACOs) under the Medicare Shared Savings Program. Specifically, the CAP had expressed concern over a reduction in the number of risk-free years for participants and a lowered maximum shared-savings rate changes. The Medicare Shared Savings Program is where most of the Medicare’s ACOs operate, which include many practicing pathologists.

In the CMS final regulation published on December 21, the Medicare agency decided to make an improvement to the risk-free period, allowing certain low-revenue ACOs three years to remain in the program without taking on risk. For others, the amount of time an ACO can remain in the program without taking on risk would still be reduced from six years to two years. The CAP was concerned that these changes would discourage ACO formation and create unnecessary hurdles for pathologists’ participation in innovative payment models.

The CAP also engaged with the CMS to maintain the maximum shared-savings rate for many ACOs at 50%. The CMS had proposed to decrease the maximum shared-savings rate to 25% based on quality performance. The CAP will continue to advocate for positive changes to the Shared Savings Program that encourage ACO formation and reduce hurdles for participating pathologists.

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After extensive advocacy from the CAP over the last five years, New York state now requires laboratory directors to be board certified. The New York State Department of Health (NYSDOH) issued proposed rules to implement this change later in 2019 after initially pledging to enforce the requirement in 2014.

The proposed rules were considered by the NYS Public Health and Planning Board on December 13, 2018. In effect, they recognize additional accrediting boards that allow certain certifications so that applicants meet the educational and training requirements needed to be a director or assistant director of a clinical laboratory or a blood bank. They also provide the DOH with more flexibility in updating the certificate of qualification categories.

The CAP has long sought greater recognition of board certification as a laboratory director qualification. In a 2013 letter sent to the NYSDOH, the CAP urged that American Board of Pathology (ABP) Board Certification in Molecular Genetic Pathology to meet the requirements for directors of high-complexity molecular biology and genetics laboratories. This followed reports that pathologists who were board-certified in molecular genetic pathology had been denied certificates of qualifications to be directors of certain laboratories by the NY Clinical Laboratory Evaluation Program.

“It is our opinion that candidates with the appropriate education and relevant training or experience that are able to achieve ABP Board Certification are fully qualified to carry out their responsibilities to patients in these laboratories,” the CAP wrote. This was supported by the ABP, which also encouraged greater recognition of board certification.

In 2014, the director of the NYS DOH pledged to ensure that board certification would be recognized, saying “I ask for your patience as we take steps to make the required regulatory changes.”

The proposed rules should be finalized in four to six months.

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The CMS replaced the login system for accessing information and reports for the Quality Payment Program (QPP). 

Pathologists using the QPP website will no longer see references to Enterprise Identity Data Management (EIDM). Instead, the CMS replaced it with the HCQIS Access Roles and Profile (HARP) system. The HARP system will replace the Enterprise Identity Data Management (EIDM) and will be used by providers to sign into the QPP website to access unique quality reporting information, such as retrieving 2017 MIPS performance reports, submitting 2018 performance year data, and determining MIPS eligibility at the group level using their Tax Identification Number (TIN). 

Pathologists that already have an EIDM login can use the same username and password to access their accounts. Moving forward, all QPP participating pathologists who log into the QPP website will manage their QPP user ID and password in the HARP portal system. If you have further questions, please contact or check out the CMS user guide.

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The CMS will host an informational call on January 22 at 2 PM ET regarding laboratory requirements for collecting data used to set future Clinical Laboratory Fee Schedule (CLFS) rates. The call will include information about mapping payments to new codes for clinical laboratory tests and other updates. 

During the call, the CMS will review the 14X TOB billing requirements, including laboratory test Healthcare Common Procedure Coding System (HCPCS) codes, associated private payor rates, and volume data requirements.

Under the 2019 CLFS final regulation, applicable laboratories must report to the CMS specific private payer rate information for their component applicable laboratories. The next CLFS data collection period, mandated by the Patient Access to Medicare Act (PAMA), is from January 1 through June 30.

You can register for the call and other informational events through the CMS’ website.

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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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