In July, when CMS released the proposed policies for physician fee schedule aka Part B, it included a proposal to review the valuation of code 88305, one of the most frequently used pathology codes. The proposal came over the transom from State of Maryland.
- Below, summaries of a white paper report written by Chat GPT on the topic.
- Find the 25-page AI report HERE.
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50-Word Summary
CMS’s 2026 scrutiny of CPT 88305 challenges a 25-minute pathologist time assumption re-surveyed and affirmed by the RUC in 2010. Maryland claims data suggest that assumption can produce impossible workdays. Historical radiology and pathology practice-expense resets show Medicare has previously rebased payment when older resource models no longer matched practice.
250-Word Summary
CMS’s 2026 review of CPT 88305 may become an unusually important test of how Medicare values pathology. The code’s 25-minute intraservice physician-time assumption is not merely a Harvard-era relic. In 2009 the RUC declined simply to defer to the original Harvard valuation, required further review, and in 2010 examined fresh survey data. That survey supported 25 minutes, while the RUC deliberately retained the existing 0.75 work RVU.
The new challenge comes from the Maryland Health Care Commission. Using claims data, Maryland multiplied billed 88305 services by Medicare’s assigned physician time and found numerous physician-days producing implausibly long, even greater-than-24-hour, nominal workdays. The issue is therefore not whether individual difficult cases can require 25 minutes, but whether 25 minutes remains credible as a typical value across real-world throughput.
The same “multiples dilemma” appears in immunohistochemistry. RUC assumptions of roughly 25 minutes for an initial stain and substantial time for each additional stain can imply around two hours or more for a modest multi-antibody panel, even when several slides are plainly negative.
A historical sidebar shows that Medicare has confronted analogous technological obsolescence before. In radiology, CMS and the RUC removed film-era practice-expense inputs and substituted digital PACS resources, causing major budget-neutral redistribution. In pathology, CMS later sharply revalued the 88305 technical component as modern laboratory production and throughput changed. The 2026 question is whether similar empirical reality checks will now reach physician work itself. If so, 88305 could become a precedent for testing RUC-derived times against actual clinical productivity across specialties.
