The 2023 Medicare Physician Fee Schedule Final Rule was released by CMS late Thursday, Nov 3. After two consecutive years of Congress delaying a number of anticipated reimbursement cuts due to the impact of the COVID pandemic, it now appears these previously planned cuts will go into effect barring any last-minute legislation to delay them further.
Conversion factor and overall charge reductions
The proposed conversion factor is $33.06, a decrease of $1.55 (4.5%) from the 2022 PFS conversion factor of $34.61. The conversion factor reductions accounts for the statutorily required 0% update for 2023, the expiration of the 3% increase in Physician Fee Schedule payments for 2022 as required by the Protecting Medicare and American Farmers from Sequester Cuts Act, and the statutorily required budget neutrality adjustment to account for changes in Relative Value Units.
Both pathology and independent laboratories are expected to see their overall allowed charges drop by about 1%.
Medicare sequestration cuts also fully resumed on July 1, 2022. This budget control mechanism was temporarily suspended during the majority of the public health emergency and partially resumed in April of this year. Since 2013, Medicare has been subject to an automatic annual “sequestration” cut of 2% as required by the Budget Control Act of 2011, which was postponed at the start of the COVID-19 PHE.
CLFS Update for Specimen Collection Fees
As part of this rule, CMS is increasing the specimen collection fee amount from $3 to $8.57 for 2023. Additionally, for a specimen collected from a Medicare beneficiary in a skilled nursing facility or on behalf of a home health agency, the collection fee will increase by an additional $2, to $10.57 total.
Potential delay must pass soon
However, some of these reductions could be delayed by the Supporting Medicare Providers Act if it passes before the end of the year. The bill would stop 4.5% of the Medicare cuts related to the budget neutrality adjustment. The proposal would also call for Congress to examine annual fee schedule changes and find a more viable solution to ease cuts moving forward.
In a bit of good news, CAP reports the CMS confirmed changes to the histotechnologist’s clinical labor rate, which will be priced in 2023 more than 21% higher than 2022. Additionally, the laboratory tech/histotechnologist blended rate will be priced more than 18% greater in 2022 than in 2023.
Below is a sampling of several popular pathology codes set to see reductions or minor positive adjustments in the 2023 Medicare Fee Schedule as currently proposed.
If you have questions about any unlisted codes, don’t hesitate to contact us for a free consultation:
2023 MPFS Sampling
| CPT Code | Service | Final 2022 | Final 2023 | % Change |
| 80503 (Non-Facility) | Path clinical consult sf 5-20 | $26.65 | $26.45 | -0.8% |
| 80504 (Non-Facility) | Path clinical consult mod 21-40 | $53.29 | $51.91 | -2.6% |
| 80505 (Non-Facility) | Path clinical consult high 41-60 | $96.55 | $93.89 | -2.8% |
| 80506 (Non-Facility) | Path clinical consult prolonged svc | $43.26 | $41.99 | -2.9% |
| 88112 – Global | Cytopath cell enhance tech | $67.48 | $65.79 | -2.5% |
| 88112 – TC | Cytopath cell enhance tech | $39.80 | $39.34 | -1.2% |
| 88112 – 26 | Cytopath cell enhance tech | $27.69 | $26.45 | -4.5% |
| 88120 – Global | Cytp urne 3-5 probes ea spec | $630.53 | $589.14 | -6.6% |
| 88120 – TC | Cytp urne 3-5 probes ea spec | $572.39 | $533.27 | -6.8% |
| 88120 – 26 | Cytp urne 3-5 probes ea spec | $58.14 | $55.87 | -3.9% |
| 88121 – Global | Cytp urine 3-5 probes cmptr | $444.00 | $413.92 | -6.8% |
| 88121 – TC | Cytp urine 3-5 probes cmptr | $395.90 | $367.63 | -7.1% |
| 88121 – 26 | Cytp urine 3-5 probes cmptr | $48.10 | $46.28 | -3.8% |
| 88184 | Flowcytometry/ 1st marker | $69.21 | $73.39 | 6.0% |
| 88185 | Flowcytometry/ additional marker | $22.15 | $23.47 | 6.0% |
| 88187 | Flowcytometry/read 2-8 | $35.99 | $34.38 | -4.5% |
| 88188 | Flowcytometry/read 9-15 | $62.98 | $60.17 | -4.5% |
| 88189 | Flowcytometry/ read 16+ | $84.44 | $81.33 | -3.7% |
| 88305 – Global | Tissue exam by pathologist | $71.98 | $70.09 | -2.6% |
| 88305 – TC | Tissue exam by pathologist | $34.61 | $34.38 | -0.7% |
| 88305 – 26 | Tissue exam by pathologist | $37.38 | $35.71 | -4.5% |
| 88307 – Global | Level V, tissue exam by pathologist | $290.69 | $285.64 | -1.7% |
| 88307 – TC | Level V, tissue exam by pathologist | $208.33 | $206.63 | -0.8% |
| 88307 – 26 | Level V, tissue exam by pathologist | $82.36 | $79.02 | -4.1% |
| 88309 – Global | Tissue exam by pathologist | $441.58 | $430.78 | -2.4% |
| 88309 – TC | Tissue exam by pathologist | $296.92 | $291.93 | -1.7% |
| 88309 – 26 | Tissue exam by pathologist | $144.65 | $138.85 | -4.0% |
| 88312 – Global | Special stains group 1 | $114.55 | $110.75 | -3.3% |
| 88312 – TC | Special stains group 1 | $88.25 | $85.30 | -3.3% |
| 88312 – 26 | Special stains group 1 | $26.30 | $25.46 | -3.2% |
| 88313 – Global | Special stains group 2 | $82.36 | $80.67 | -2.1% |
| 88313 – TC | Special stains group 2 | $70.25 | $69.10 | -1.6% |
| 88313 – 26 | Special stains group 2 | $12.11 | $11.57 | -4.5% |
| 88341 – Global | Immunohistochemistry (add stain) | $89.63 | $84.97 | -5.2% |
| 88341 – TC | Immunohistochemistry (add stain) | $61.60 | $57.86 | -6.1% |
| 88341 – 26 | Immunohistochemistry (add stain) | $28.03 | $27.11 | -3.3% |
| 88342 – Global | Immunohisto antibody 1st stain | $102.43 | $98.52 | -3.8% |
| 88342 – TC | Immunohisto antibody 1st stain | $67.83 | $65.13 | -4.0% |
| 88342 – 26 | Immunohisto antibody 1st stain | $34.61 | $33.39 | -3.5% |
| 88367 – Global | Insitu hybridization auto | $114.89 | $112.08 | -2.4% |
| 88367 – TC | Insitu hybridization auto | $81.33 | $80.01 | -1.6% |
| 88367 – 26 | Insitu hybridization auto | $33.57 | $32.07 | -4.5% |
| 88368 – Global | Insitu hybridization manual | $138.08 | $140.18 | 1.5% |
| 88368 – TC | Insitu hybridization manual | $96.90 | $100.17 | 3.4% |
| 88368 – 26 | Insitu hybridization manual | $41.18 | $40.00 | -2.9% |
| G0416 – Global | Prostate biopsy | $358.52 | $354.41 | -1.1% |
| G0416 – TC | Prostate biopsy | $180.99 | $183.82 | 1.6% |
| G0416 – 26 | Prostate biopsy | $177.53 | $170.59 | -3.9% |
| G0452 – 26 | Molecular path interp | $46.03 | $45.62 | -0.9% |
| P3001 | Screening pap smear by phys | $22.49 | $22.48 | 0.0% |