Sunday, June 18, 2023

Digitalization of Pathology Slide Codes: AMA Says OK, CMS Outpatient Rules say "Nix"

HEADER: The article discusses the new codes established by AMA for the digitalization of pathology slides.   The codes, though not priced on the Part B fee schedule, are actually classed as unpayable in the hospital outpatient setting, where many surgical specimens originate.


Effective January 1, 2023, AMA created over a dozen new codes for digitalization of pathology slides in numerous contexts.  See two articles at CAP, an overview here and a deeper dive here.  The latter article lists the full text of all the codes.

They're Category III codes, so they don't go to the AMA RUC for RVU valuation, and won't be valued in RVU's on the Part B fee schedule.   However, the CMS hospital outpatient system is also driven by CPT codes, and nearly all CPT codes, including Category III codes, get evaluated for pricing in that system.

What did the CMS Outpatient Policy people decide about these codes?  None of them are accessible for payment in the hospital outpatient setting.  They all have a "status N" designator, simply, not payable.

Here they are, from 0751T to 0763T, all status "N" non payable.

Outpt App B APC Rules / 1 1 2023

I don't believe the categorization of these rules was discussed last autumn (nothing in final OPPS rule 11/12/22, 87 FR 71748,but see listing of the "N" status in 1/2023 in CR12998), so they'll likely be discussed soon, in the July 1 outpatient rulemaking for CY2024.  We'll follow upThe "N" status wasn't discussed in the July 2023 OPPS rule, either.

These "N" rules are binding on specimens that originate in hospital outpatient settings, but not in ASC (to my knowledge) or freestanding office settings (Part B).  As of 6/2023, I didn't see any documents listed giving Part B policy in any MAC for 0751T etc on the CMS policy database.


AMA is still at it.  At the May 2023 CPT meeting, they created yet 30 more Cat III dig path codes.  These will be released publicly on July 1, in ten days.