Federal
HHS Proposed Implementation of ICD-10 Code Sets
The Department of Health and Human Resources has announced a plan to mandate the implementation of the International Statistical Classification of Diseases and Related Health Problems, 10th Revision (ICD-10) for all physician practices and clinical laboratories by October 1, 2011.
This proposed regulation would replace the ICD-9 code sets currently in use, which were developed nearly 30 years ago and are now widely viewed as outdated because of their limited ability to accommodate new procedures and diagnoses. ICD-9 contains only 17,000 codes and is expected to begin running out of available codes next year. By contrast, ICD-10 contains more than 155,000 codes for classifying a host of new procedures and diagnoses. HHS hopes that the additional new codes will aid implementation of electronic health records because they will provide greater detail in electronic transactions.
The changeover is being met with mixed reviews within the health industry. While ICD-10 brings a significantly more robust coding system that will ultimately serve to improve our nation’s diagnostic and procedure data, implementation promises to be both tedious and costly. A study authored by the Nachimson Advisors and commissioned by nine associations of health care providers estimates that a large national laboratory would have to spend approximately $40 million to upgrade its system to comply with the new rule.
ASCP has joined nearly 40 other medical societies in a letter to HHS urging the development of a realistic timetable for implementation; one that avoids negatively impacting health services to patients by recognizing the challenges and requirements associated with this transition.
ASCP Appeals Reimbursement Recommendations for New Lab Tests
On October 10th, ASCP wrote the Centers for Medicare and Medicaid Services (CMS) appealing the agency’s initial reimbursement determinations for several new laboratory tests that will be added to the clinical laboratory fee schedule on January 1, 2009. At issue: What is the best “crosswalk” CMS should use to value new tests? The crosswalking process, one of two approaches used by CMS to determine reimbursement for laboratory tests, attempts to determine the best comparison between a new test and an existing test in terms of testing methodology, resources used, costs, clinical outcomes, etc. ASCP raised concerns about the methodology used by CMS to value and reimburse these new tests.
ASCP argued that CMS should increase reimbursement for new CPT code 83876, Myeloperoxidase (MPO) to $47.32, rather than the $18.09 initially recommended by the agency. We also urged that $89.32 be provided for new CPT code 83951, Oncoprotein; des-gamma-carboxy-prothrombin (DCP) instead of $43.32. Additionally, the Society recommended increasing reimbursement for new CPT code 85397, coagulation and fibrinolysis, functional activity, not otherwise specified (e.g., ADAMTS-13), each analyte, to $32.06, rather than CMS’ initial recommendation of $25.02. For a copy of ASCP’s letter appealing the CMS payment recommendations, click here.
CMS Publishes Most Medical Unlikely Edits Online
As the result of pressure from ASCP and other advocacy groups, CMS recently released many of its Medically Unlikely Edits (MUE) online. The MUE program is part of the National Correct Coding initiative, one of CMS’ anti-fraud initiatives. Though pathology and laboratory medicine were never intended as a principal target of the program, the industry was caught in the Agency’s plans for dealing with Medicare program abuse. CMS has not released all of the MUE limitations developed so far. Due to concerns about fraud and abuse, the agency is only releasing units of service limitations on those services that have a MUE edit of less than 4 (per patient, per day) at this time.
Of the more than 8,000 MUE limitations CMS has released, approximately 900 relate to pathology and laboratory medicine. To obtain a copy of the MUE limitations, click here.
State News
ASCP Appeals Florida Board Interpretation
ASCP recently wrote to the Florida Board of Clinical Laboratory Personnel urging reconsideration of a Departmental interpretation of the Board’s rules. Earlier this year, the Board was queried whether laboratories must utilize licensed molecular pathology technologists to perform PCR testing for Methicillin-resistant Staphylococcus aureus (MRSA) or Group B streptococcus (GBS). Several Board staff indicated that molecular pathology technologists must be used to perform all molecular detection techniques. In its letter to the Board, ASCP argued that the addition of the molecular pathology technologist license was never intended to adversely affect the scope of practice of other laboratory practitioners. Moreover, ASCP argued that the Department’s interpretation was inconsistent with the rules since the scope of practice for molecular pathology technologists was limited to the analysis of human genetic material, and thus should not have hampered testing for MRSA or GBS. This issue is expected to be discussed at the November 14th Board meeting.
Society News
Annual Meeting Session Examines How Medicare is Evolving for Pathology
During the 2008 ASCP Annual Meeting in Baltimore, the Society’s Fellow Council, chaired by David C. Chhieng, MD, MBA, FASCP, held a special interactive breakfast forum that addressed some of the most pressing policy issues facing the field of pathology. The session: Medicare on the Brink: How Pathology Can Survive the Baby Boomer Bust looked at how policy is affecting the field of pathology and how pathologists and laboratory professionals will need to be prepared to address the future of the profession. ASCP leaders, including ASCP’s new President Barbara J. McKenna, MD, FASCP, and Immediate Past President, Lee H. Hilborne, MD, MPH, FASCP, DLM(ASCP)CM, discussed the evolution of technology and its effect on the profession; policy initiatives such as Medically Unlikely Edits, Competitive Bidding for Laboratory Services and Pay for Performance; and changing practice patterns, reimbursement, and the business of pathology.
ASCP Announces Public Policy Fellowship/Internship Program
The American Society for Clinical Pathology’s (ASCP) is announcing the establishment of its public policy fellowship & internship program. ASCP policy fellows and interns will work on laboratory and health policy at ASCP’s Washington, D.C. Office. The program is a great opportunity for individuals interested in health policy, public health, and politics to learn more about these issues.
The ASCP fellowship program is suitable for undergraduate graduate and post-graduate individuals, as well as individuals who are not currently matriculating in an academic or clinical program. Participants will receive a stipend dependent on their availability. Fellowships and internships typically last between 8-12 weeks, however, this schedule may vary depending upon ASCP need and student availability. Individuals interested in applying for the program may contact Matthew Schulze at 202.347.4450 or by e-mail at matthew.schulze@ascp.org for details.