Friday, June 26, 2026

Digital Pathology Association/DPA Issues Two Linked Documents on AI Validation and Reimbursement

Digital Pathology Association Issues Two Linked Documents
on AI Validation and Reimbursement

1. Recommendation Statement for the Validation, Implementation, and Clinical Application of Artificial Intelligence Within a Clinical Laboratory from the Digital Pathology Association

https://journals.sagepub.com/doi/10.1177/2993091X261455975

2. Full Speed Ahead: Shaping the Future of Digital Pathology Reimbursement in 2026
https://digitalpathologyassociation.org/blog/full-speed-ahead-shaping-the-future-of-digital-pathology-reimbursement-in-2026

[chat GPT 5.5]

The Digital Pathology Association (DPA) has recently issued two important and closely linked documents. The first is a formal recommendation statement, published in AI in Precision Oncology, Silberman et al., on validation, implementation, and clinical use of AI in digital pathology. The paper addresses analytical validation, clinical validation, scanner and algorithm performance, pathologist oversight, clinical utility, and real-world reliability.  (I covered this 27-page paper in detail earlier.)

The second is an April 6, 2026 DPA Reimbursement Task Force webpage outlining the association’s 2026 policy agenda for digital pathology reimbursement. It frames reimbursement and market access as central barriers to adoption, and states that DPA’s goal is to define and shape the pathway to reimbursement for digital pathology solutions.

The linkage between the two is explicit:

DPA presents the Silberman validation paper not only as a clinical roadmap for laboratories, but also as an evidence base for reimbursement. In DPA’s formulation, payers will not pay simply because AI is interesting or efficient. The field must show that digital pathology AI is safe, validated, clinically meaningful, and important to patient care.

The April 6 policy page is especially notable because it signals a more organized reimbursement strategy. 

DPA says it has partnered with McDermott+ to monitor and influence CMS, AMA, Congress, and other policy venues. The stated goal is to promote positions supporting coding, coverage, payment, and adoption of digital pathology technologies and infrastructure through official comment and direct agency engagement.

DPA writes, "We are no longer just reacting to policy - we are proactively influencing and shaping the future reimbursement framework. 

Take home lesson: 

For readers following digital pathology, this burst of activity is worth watching. The validation paper supplies the scientific and clinical framework; the reimbursement page describes the policy machinery DPA intends to build around it. Together, they suggest that DPA is trying to move digital pathology from promising technology toward a reimbursable, policy-recognized clinical infrastructure.

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Sidebar: Reimbursement Task Force
https://digitalpathologyassociation.org/reimbursement-task-force

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Sidebar: Conference

The DPA "Pathology Visions" conference will be October 16-18 in San Diego.

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Sidebar: CMS and Software Valuation

Last summer, CMS issued RFIs (requests for information) in both Physician/PFS and Outpatient Hospital/OPPS rules.  Responses were due by September; CMS merely acknowledged the receipt of numerous responses in the November final rules.  We may see more in July 2026 policymaking for PFS and OPPS.

Last December, HHS issued an RFI for clinical AI which asked about (1) regulation, (2) R&D, and (30 Reimbursement.  HHS held a webinar yesterday (June 25) highlighting its activities in some of these areas, but leaving "reimbursement" out of scope. 

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Sidebar: The DPA in 2023 and in 2026

DPA has had policy articles twice in 2023, then none in 2024 or 2025, and now this new reimbursement program of activity in 2026.  


Chat GTP compares the 2023 and 2026 blog here.  Concisely it concluded:

DPA’s October 2023 reimbursement article was a sophisticated but technical map of possible payment pathways, centered on the then-new Category III slide digitization codes but extending into CMS authority, HCPCS alternatives, OPPS software pa

 

yment, and the need for valuation data.

The April 2026 article is different. It is shorter, less technical, and more strategic. Rather than explaining the maze, it announces that DPA is building the machinery to navigate it: a validation/evidence statement for AI, a more explicit reimbursement mission, and a policy partnership with McDermott+ to engage CMS, AMA, Congress, and other decision-makers. In that sense, the 2026 piece reads less like a reimbursement tutorial and more like an organizational reboot.