Wednesday, June 21, 2017

Brief Blog: Medicare Payments for Pathology Slide Consultations in CY2015

Medicare recently released a database of all provider payments by CPT code in CY2015, here.

Pathology Slide Consultation Codes
Code 88321 pays about $90 for review of slides prepared elsewhere.  There were 181,427 services totalling $17,043,561 in allowed charges.   88325 is for "comprehensive" review (e.g. with medical records or imaging), paying about $180.  There were 8,224 services totalling $1,513,496 in allowed charges.  These are from summary 2015 data of all Part B services.

The provider payment database is just a bit different as it excludes providers with <10 services per CPT code.  Here, in this database, I tally $17,037,639 services for 88321+88325.   The top 10 providers were 19% of payments and the top 15 were 22% of payments.

Academic Institutions 
The top provider was Johns Hopkins ($690,728).  The third top was UCSF Dermatology ($555,931).  The sixth top was Washington University ($186,959) - showing that the dollars drop off pretty fast.

Not Academic Institutions
The second top provider was a medical corporation in California, enrolled as a clinical lab, $621,878.  The fourth and fifth top were individual doctor names, enrolled as dermatologists, one in Colorado, one in California, receiving $315,802 and $248,187, respectively.  The seventh-top provider was a California dermatologist.  Three of the top 7 providers were dermatology practitioners or groups.  According to AMA RUC online data, only 8% of all 88321 billings were from dermatology, but if they bill, they can be very active.

The AMA RUC database, which is copyrighted, provides a very lengthy RUC panel discussion and rationalization for payments on 88321, describing it as part of a 2016 CMS screen for high cost services > $10M.

The RUC states in part, and I hope this is a fair use short extract, "The RUC reviewed the survey results from 52 pathologists and recommends the following physician time components: pre-service time of 0 minute, intra-service time of 50 minutes and immediate post-service time of 0 minute. The RUC reviewed the survey respondents’ estimated work values and agreed that the specialties’ recommendation to maintain the current work value of 1.63 is appropriate for this service. The RUC compared the service to key reference service CPT code 88307, Level V - Surgical pathology, gross and microscopic examination."  Accordingly, the database physician time assessment for 88321 is 50 minutes.  (88325 is valued for 90 minutes).  This suggests dermatologists billing 1000-2500 service units spent 833-2,083 hours per year doing consult slides, or 3 hrs to 8.5 hrs per each M-F workday.  (A standard work-year of 50 weeks x 40 hours is 2000 hours).  This would be a record of only their Medicare Part B practice.   In some cases, what appears as single physician billing might be rolled up from several in a group practice, I think.

Tidbit. Each single immunohistochemistry slide is valued by the RUC at 25 minutes (CPT 88342; same for 88341 for 2nd and add'l slides), suggesting each tray of 10 such slides requires almost 5 hours to sign out.